2017 (9) TMI 97

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....nder Singh, Member (Technical) Adjournment request - for the Appellant Shri Vijay Gupta, A.R. for the Respondent ORDER Per : Archana Wadhwa After rejecting the request for adjournment, we proceed to decide the stay petition as also appeal inasmuch as, the matter has been repeatedly coming up on board and was being adjourned at the requests of the appellant. 2. We find that servic....

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....tion as also before appellate authority, the appellant took a categorical stand that the said payments were made to their holding and subsidiary companies located in foreign land, on account of travel expenses of their employees who visit the foreign country and as a convenience, the arrangements are made by the holding company. They also produced certain documents on record, which were not found ....

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.... making a bald allegation that such expenses were for promoting their business from India, have also not referred to any basis for entertaining the above view. If the Revenue is making an allegation, the onus to establish the allegation is upon them. We note that there is no reference to any services having been provided by the holding company for promoting the assessee s business from India. 6....