2021 (2) TMI 272

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....ance premium paid for the family members of the employees of the company on the ground that such expenditure though incurred in terms of contractual obligation with the employees, However, it cannot be stated to have been incurred wholly and exclusively for the purpose of the business of the assessee, was confirmed by the ld. CIT(A). Therefore assessee is in appeal. 3. The assessee submitted written representation stating that above issue is squarely covered in favour of the assessee by the order of the co-ordinate bench in assessee's own case for Assessment Year 2010-11 wherein the identical claim of the assessee was allowed. Further for Assessment Year 2013-14 the ld. CIT (Appeals) himself following the order of the co-ordinate ben....

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....e material available on record, we find considerable substance in the contention of the assessee. The record reveals that the assessee had paid the insurance premiums of the employees' family members in terms of employment Rules framed by the assessee-company there for. Therefore, it can hardly be said that the impugned expenditure were not incurred wholly and exclusively for the purpose of business, which is the real intent of Section 37(1) of the IT Act. The ld. Authorities below could not bring any evidence on record to substantiate that tin. payments so made by the assessee-company had no nexus with the business of the assessee. Even otherwise, it is not necessary that all the payments/expenditure incurred by the assessee should hav....