2018 (7) TMI 2068

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....Income Tax Act, 1961(hereinafter 'the Act'). 2. At the outset, the learned Counsel for the assessee Shri Rajan Vora, submitted that this is a recall matter and Tribunal in MA No. 719/Mum/2017 dated 31.05.2018 has recalled the matter regarding grounds No. 5 to 7 which is not been adjudicated. Hence, now only grounds No. 5 to 7 are to be adjudicated. 3. The only issue in these ground Nos. 5 to 6 of the assessee's appeal is as regards to the order of CIT(A) confirming the action of the AO in making disallowance of payments made to M/s Cox and Kings amounting to Rs. 8,24,13,778/-. For this assessee has raised the following ground Nos. 5 & 6 as under: - "Disallowance of payment made to CKIL under section 40a(ia) of the Act 5. erred in ....

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....ness. Being in the initial phase of business the assessee was required to incur certain expenses in order to make its footprint in the tour and travel industry. Accordingly, the Assessee incurred expenses and overheads amounting to Rs. 8,24,13,778/- such as advertisement expenses, bandwidth charges, professional charges, consultancy charges, salaries, rent expenses, etc. Such expenses were directly related to the business of the Assessee and were required to be incurred by the assessee for running its business and making a place for itself in the tour and travel industry. CKL, being a sister concern of the assessee and being in the same line of business, extended assistance to the assessee on its initial phase by providing access to its inf....