2013 (10) TMI 523

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.... This appeal by the assessee arises out of the order passed by the CIT(A) on 16-09-2011 in relation to the A.Y. 2008-09. 2. The first ground is against the confirmation of the action of the Assessing Officer in making disallowance of Rs.4,99,736/- u/s 40(a)(i) of the Income-tax Act, 1961 (Act). Briefly stated the facts of this ground that the assessee claimed deduction for foreign consultancy....

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....ecord, it is observed that the authorities below have covered this amount u/s 9(1)(vii) as, 'fees of technical services' in the nature of 'inspection services' for purchase order. The Ld. AR contended that the authorities have gone by the nomenclature given in the Agreement without ascertaining correct nature of amount which was simply in the nature of commission. From the orders of the authoritie....