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ITAT held that the assessee failed to discharge the onus of substantiating its claims of expenditure on service fees paid to KMCCL and legal fees paid to M/s CAM, as no enforceable agreements, correspondence, or supporting documents were produced before the lower authorities. However, considering that the issues had not been adjudicated with complete evidence, ITAT remanded both issues to the Commissioner for de novo adjudication. The Commissioner is directed to reconsider the disallowances after affording a reasonable opportunity of hearing, while the assessee is directed to file all relevant agreements and communications, failing which no leniency shall be extended regarding the claimed deductions.
ITAT held that the assessee failed to discharge the onus of substantiating its claims of expenditure on service fees paid to KMCCL and legal fees paid to M/s CAM, as no enforceable agreements, correspondence, or supporting documents were produced before the lower authorities. However, considering that the issues had not been adjudicated with complete evidence, ITAT remanded both issues to the Commissioner for de novo adjudication. The Commissioner is directed to reconsider the disallowances after affording a reasonable opportunity of hearing, while the assessee is directed to file all relevant agreements and communications, failing which no leniency shall be extended regarding the claimed deductions.
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