2022 (9) TMI 646

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....AL, VP : This appeal by the Revenue arises out of the order passed by the CIT(A)-5, Pune on 16-05-2019 in relation to the assessment year 2016-17. 2. The only issue raised herein is against the deletion of addition of Rs.2,64,61,769/-, being, the payment made by the assessee to Tata Autocomp Systems Ltd. ('TACO') on account of Administrative Service charges. 3. Succinctly, the facts of th....

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....e was produced by the assessee to substantiate the claim of receipt of the services. He further noticed that the assessee itself incurred administrative and other expenses. The AO also took note of the fact that the payment to TACO was in lieu of the services at the start up phase and Operational phase and that the services in the Operational phase were general in nature not requiring any technica....

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....ead 'Human Resource and Development', the assessee has referred to various e-mails exchanged during the year between it and TACO concerning with the human resource development. Such detailed e-mails have been placed on record in second and third paper books. We have examined some of the e-mails on test-check basis and found the same to be pertaining to the assessee's business. Similar is the posit....