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TMI Blog2022 (6) TMI 1267X X X X Extracts X X X X X X X X Extracts X X X X ..... s, and various clearing charges from Naval custom authorities to upgrade the Vessel so as to qualify as per Seismic norms prescribed under the contract - HELD THAT:- AO submitted before the lower authorities that the payment made by the assessee was duly shown as receipt by the ship owner company as its income and offered the same to tax. The ld. AR placed on record the profit and loss account and balance sheet of the ship owner company wherein this sum was included as income under the head sale of services as on 31/03/2014 in the audited financial statements and a Chartered Accountant Certificate dated 27/12/2017 was also furnished in the prescribed format stating that recipient had duly offered to tax the said sum of Rs.2,57,55,269/- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 016 by the ld. Income Tax Officer 1(1)(2), Mumbai (hereinafter referred to as ld. AO). 2. The only issue to be decided in this appeal is as to whether the ld. CIT(A) was justified in confirming the disallowance of expenditure representing reimbursement thereon u/s.40(a)(ia) of the Act in the facts and circumstances of the instant case. 3. We have heard rival submissions and perused the materials available on record. The assessee Company is in the business of providing Marine Seismic Services used for Research and Development to explore the utilisation of recourses available in sea and also provide complete Survey Solution including Bathmetry, Fishing Managements, Chase Boats and other related logistic services for data processing ser ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ded that the said mobilisation expenses of USD 255,000 is nothing but reimbursement of expenses incurred while vessel was made available for conducting seismic survey in Oman from India. The Ship Owner Company also billed stand by charges of USD 173,541.67 as stated in Invoice No.3670/HOPL/2014 which was nothing but the reimbursement cost towards vessel made available at the field for operation to the Company. Eventually, such reimbursement cost incurred towards port charges, victualising charges, on board crew salary, fuel, fresh water consumption etc. during the stand by period at operational field. In view of these facts, the assessee company has paid Rs.2,57,55,269/- as per Invoice and debited to Hire Charges (Geo Hindsagar ). The fact ..... X X X X Extracts X X X X X X X X Extracts X X X X
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