2021 (5) TMI 523

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....foresaid matter is a recalled matter since the appeal was earlier disposed-off ex-parte qua the assessee vide Tribunal order dated 29/05/2019. However, the order has been recalled vide MA No. 555/Mum/2019 order dated 13/03/2020. Accordingly, the appeal has come up for fresh hearing before this bench. 2. In this appeal for Assessment Year (AY) 2014-15, the assessee is aggrieved by confirmation of ....

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....td. on sales lead received in the ratio of 90:10 out of total expenditure incurred by the related party. However, the assessee failed to furnish the details of customers generated out of sales leads. The assessee could not show how the sales were improved with the sale leads. In the absence of sufficient documentary evidences, the amount of Rs. 21.77 Lacs was disallowed u/s. 40A(2)(b). The stand o....

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.... for AY 2016-17 was framed u/s. 143(3) wherein similar claim made by the assessee was accepted. Further, payer as well as payee, both are in highest tax bracket and therefore, the invocation of provisions of Sec. 40A(2)(b) would not be justified. Hence, on the facts and circumstances of the case, we are inclined to delete this addition. The ground raised by the assessee stand allowed. 5. Disallow....