https://www.taxtmi.com/caselaws?id=71163 Consultation fees paid for technical assistance were treated as commercially justified where the consultant's services were actually used, the work required specialised expertise, and the recipient had relevant professional experience; on that basis, disallowance as excessive under section 40A(2)(b) was deleted. For relief under section 80J, borrowed capital was included in computing capital employed because the expression was not confined to owned funds; this interpretation supported the assessee's claim. The note therefore records that both disputed adjustments were decided in favour of the assessee. en-us Mon, 24 Sep 1979 00:00:00 +0530 Thu, 21 Apr 2011 16:33:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=71163 Consultation fees paid for technical assistance were treated as commercially justified where the consultant's services were actually used, the work required specialised expertise, and the recipient had relevant professional experience; on that basis, disallowance as excessive under section 40A(2)(b) was deleted. For relief under section 80J, borrowed capital was included in computing capital employed because the expression was not confined to owned funds; this interpretation supported the assessee's claim. The note therefore records that both disputed adjustments were decided in favour of the assessee. Case-Laws Income Tax Mon, 24 Sep 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=71163