2015 (4) TMI 1244

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.... Accordingly for the sake of convenience the issues are being decided by a common order. The Hon'ble High Court vide the above order was pleased only to restore these two appeals addressed in ITA No.-124/2008 & 1283/2010 for 2003 & 2004-05 assessment years with the following observations:- 9. "Insofar as claim of foreign travelling expenses in this year is concerned, the order of the Tribunal reveals that the Tribunal has simply followed the order in the earlier assessment year and there is no discussion and no finding of fact on the basis of material on record is recorded as to whether any foreign travel expenses were incurred for the purpose of business in this year or not. Therefore, the matter needs to be remitted back to t....

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....he details of foreign travel along with purpose of the travelling. In its explanation, the assessee company has claimed that all the journeys have been undertaken for the purpose of business and has provided reasons thereof vide its submission dated 14.11.2005. The assessee company is also running an STP-I unit on which it has claimed deduction u/s 10A of the IT Act, 1961 and the expenditure on travel cannot be properly bifurcated. This issue has been discussed at length during assessment proceedings for the Assessing Years 2001-02 and 2002-03 wherein 50% of the expenses of travelling were disallowed. The additions has been confirmed by the Ld. CIT(A). I have no reason to differ with the findings of the earlier years and 50% of the expenses....