TaxTMI 
TaxTMI 
2018 (7) TMI 1822
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.... both the appeals for our consideration: "(a) Whether on the facts and in the circumstance of the case and in law, the Tribunal was justified in law in upholding disallowance of the royalty payment made to G4S NAMESA by the appellant on the ground that the same was not incurred wholly and exclusively for the purpose of business under Section 37 of the Act ? 3. The respondent-assessee is engaged in the business of providing various expert advisory and other security related services across the globe since over last four decades. The respondent had for Assessment Year 2008-09 and 2009-10 claimed as revenue expenditure the amount paid to its Associate Company, M/s. G4S Regional Consultancy Services, Bahrain (M/s. G4S, NAMESA) for providing v....
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....arried the issue in Appeal to the Tribunal. The impugned order of the Tribunal holds that though the respondent has produced the copy of the agreement dated 27th December, 2007 under which it claims to have acquired technical know-how, but the respondent was not able to establish how the agreement was put to use in the business of the assessee. In the aforesaid circumstances, the impugned order holds that as the respondent had failed to explain how the agreement dated 27th December, 2007 entered into by it with M/s. G4S NAMESA had facilitated its business. Thus, upholding the view of the CIT (A), that the expenses cannot be allowed as business expenditure because it was not expended wholly and exclusively for business purposes. 6. Ms. Sath....