Managing Director's Pay u/s 40A(2) Scrutiny; Tribunal Fails to Prove Lack of Evidence for Business Role.

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....Addition u/s 40A(2) - remuneration paid to the Managing Director nearly 90% of the returned income of the assessee company - CIT (Appeals) as well as the Tribunal have completely failed to establish that no material was produced by the assessee to demonstrate that the Managing Director had secured the business of the company from Italy and other European countries. The provisions of Section 40A(2) which are applicable to the fact situation of the case have also not been taken into account by the CIT (Appeals) as well as the tribunal. - HC....