2021 (10) TMI 734

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....y the revenue: "1. On the facts and in the circumstances of the case, the ld. CIT(A) has erred in allowing partially claim of expenses incurred in Russia for realization of contracts in India on the ground of additional evidences admitted for the assessment year 2006-07. 2. On the facts and in the circumstances of the case, the ld. CIT(A) has erred in admitting the claim of Assessee about the expenses incurred in Russia for realization of contracts in India without any additional evidences in support of expenses and also by not allowing any opportunity to the AO for rebuttal of the hypothetical grounds of the Assessee. 3. Without prejudice to the above, whether the ld. CIT(A) has erred in allowing claim of expenses incurred in Russia ....

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..... In absence of the reliable details, the genuineness of these expenses could not be verified. 7. The only issue involved is deductibility of expenses against income attributable to Indian PE when these expenses are claimed to have been entered in books of accounts of head office in Russia. The appellant claimed before AO that these expenses were actually incurred by parent company in Russia in relation to projects in India. Debit notes were raised and sent to India. These debit notes were certified by Russian auditors and these were passed through books of accounts maintained in India. The AO disallowed these expenses on the ground that no details thereof were furnished and also no TDS was made and therefore these were not to be allowed a....