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TMI Blog2020 (2) TMI 1627X X X X Extracts X X X X X X X X Extracts X X X X ..... e arguments of double taxation and the fact of TDS is negated. Any expenditure cannot be disallowed unless it is found to be not wholly and exclusively incurred for the purposes of business. The Assessing Officer, is, therefore, directed delete the disallowance on this account. Appeal of assessee allowed. - ITA No. 9626/DEL/2019 - - - Dated:- 25-2-2020 - Shri H.S. Sidhu, Judicial Member And Sh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee did not find any favour with the Assessing Officer who disallowed the bonus u/s 36(i)(ii) of the Income-tax Act, 1961. 6. The assessee carried the matter before the ld. CIT(A) but without any success. 7. Before us, the ld. counsel for the assessee stated that similar disallowances were made in Assessment Year 2013-14 and 2014-15. It is the say of the ld. counsel for the assessee t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... years but were directed to be deleted. The relevant findings of the DRP in Assessment Year 2013-14 read as under: Having considered the fact of the case and material on record, as well as the judicial pronouncement the DRP finds that there is no merit in the AOs contention, even if the assessee arguments of double taxation and the fact of TDS is negated. Any expenditure cannot be disallowed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee Company (by virtue of not allowing the deduction) and the recipient. 7.5 In this case, the similar payment has been allowed by the DRP, which comprises of three Commissioners. Vide Para 4.3 of the order of the DRP-1, New Delhi in the case of the Appellant for AY 2013-14, order dated 31.08.2017, the issue has been decided as under : Having considered the fact of the case and mat ..... X X X X Extracts X X X X X X X X Extracts X X X X
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