https://www.taxtmi.com/caselaws?id=445391 ITAT Ahmedabad allowed the assessee's appeal on multiple grounds. The tribunal upheld CIT(A)'s decision allowing corporate service charges paid to holding company, finding adequate documentation and comparative analysis supported the claim. Service charges under section 40(A) were also allowed as AO failed to demonstrate unreasonableness and made ad hoc disallowance without basis. Addition for unaccounted production of pharmaceuticals was deleted as assessee provided auditor-certified captive consumption details. Salary disallowance for seconded employees was rejected following consistency principle since employees were seconded in earlier years and continued employment. The tribunal noted assessment year 1994-95 records were affected by floods, making complete documentation impossible. en-us Tue, 31 Oct 2023 00:00:00 +0530 Mon, 06 Nov 2023 11:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445391 ITAT Ahmedabad allowed the assessee's appeal on multiple grounds. The tribunal upheld CIT(A)'s decision allowing corporate service charges paid to holding company, finding adequate documentation and comparative analysis supported the claim. Service charges under section 40(A) were also allowed as AO failed to demonstrate unreasonableness and made ad hoc disallowance without basis. Addition for unaccounted production of pharmaceuticals was deleted as assessee provided auditor-certified captive consumption details. Salary disallowance for seconded employees was rejected following consistency principle since employees were seconded in earlier years and continued employment. The tribunal noted assessment year 1994-95 records were affected by floods, making complete documentation impossible. Case-Laws Income Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445391