2018 (11) TMI 122

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....see has challenged disallowance of Rs. 7,79,328 out of expenses incurred on support service. The facts in brief are that assessee company has paid support services expenses to M/s. Geoworks Realty Pvt. Ltd. for sums amounting to Rs. 7,79,328/-. Ld. AO required the assessee to furnish the details / nature of services provided by the said company and also to justify the said payment in respect of carrying out the business activities. In response, the assessee submitted that it had utilized various services of M/s. Geoworks Realty Pvt. Ltd. like infrastructure and support services including part of office space, reception, printing, phone expenses, documentation work and other misc. expenses. However, the Ld. AO noted that under 'fixed asse....

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....,5811-, printing and stationary for Rs. 7903/-, Misc. General expenses for Rs. 17,309/-. Therefore, it is beyond belief that assessee company has availed support services from MIs GRPL. v. The assessee company has provided bifurcation of revenue received during the year and the details is as under.- Interest income Rs. 7,83,065/- Amount forfeited Rs. 30,00,000/- Other Rs. 45,091/- On perusal of above receipts, it is observed that for the above activities no particular support service is required. " After making aforesaid observations, he has disallowed the entire claim of the assessee. 3. Before the Ld. CIT (A) the assessee placed the entire material and facts on record and pointed out that M/s. GRP....

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.... software, internet, Anti- Virus support & AMC cost. 4 Use of Photocopier for photocopy of documents, office stationery for their Day to day work. 5 Documents writing and support services were also being rendered by GRPL. 6 Rendering Staff support services of Receptionist, Accounts, HR, Marketing and Field Executive. 7 It is also includes day to day tea, snacks and other. misc. expenses borne by GRPL 8. Fee:Rs: 60,000/- + Service Tax as applicable. 9 Confidentiality: Both the parties are agreed that they will not disclose any of the terms .and condition of this work order to the other party or its representatives or affiliates without the written consent of M/s HPL Infrastructure Pvt. Ltd 10 Resolut....