2011 (7) TMI 956

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....ntant Member - This appeal by the Revenue is against the order of the CIT(A)-III, Mumbai dated 20.10.2009. 2. Assessee is a partnership firm of Chartered Accountants and in the scrutiny assessment, the A.O. considered that payment made to certain consultants engaged by the Chartered Accountants' firm are in the nature of fees for professional services and accordingly provisions of section 19....

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....ssessee has not deducted the tax, the amounts claimed of Rs. 26,75,535/- was to be disallowed under section 40(a)(ia). The matter was carried to the CIT(A) who, after examining the issue and submissions of the assessee, deleted the addition by stating as under: - "3.7.1. There is merit in this submission of appellant. The deduction of tax made by appellant though made u/s. 192 has not been disp....

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....could have been considered as liability under the I.T. Act and as due from the appellant. Disallowance of the entire expenditure of Rs. 26,75,535/- whose genuineness has not been doubted by the AO is not justifiable." 3. We have heard the rival arguments and examined the record. Assessee has employed about 18 consultants with whom it entered into agreements for a period of two years renewable f....