https://www.taxtmi.com/caselaws?id=753183 ITAT Mumbai remanded two issues back to AO for fresh examination. First, regarding consultancy fee payment to Dr. Abhishek Shukla, the court held that business expenditure is allowable even if no revenue results that year, but assessee must substantiate business purpose and scope of work. Since documents were unavailable to AO and CIT(A), matter was restored for fresh consideration with onus on assessee to prove business purpose and nature of services. Second, regarding subscription fee disallowance under section 40(a)(ia) for non-deduction of TDS, the court noted invoice showed annual subscription renewal and remanded to AO, indicating no TDS required if subscription fee nature established. Appeal allowed for statistical purposes. en-us Fri, 17 May 2024 00:00:00 +0530 Mon, 27 May 2024 18:25:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753183 ITAT Mumbai remanded two issues back to AO for fresh examination. First, regarding consultancy fee payment to Dr. Abhishek Shukla, the court held that business expenditure is allowable even if no revenue results that year, but assessee must substantiate business purpose and scope of work. Since documents were unavailable to AO and CIT(A), matter was restored for fresh consideration with onus on assessee to prove business purpose and nature of services. Second, regarding subscription fee disallowance under section 40(a)(ia) for non-deduction of TDS, the court noted invoice showed annual subscription renewal and remanded to AO, indicating no TDS required if subscription fee nature established. Appeal allowed for statistical purposes. Case-Laws Income Tax Fri, 17 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753183