2023 (11) TMI 133

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.... Standing Respondent Through: Mr A.T. Panda, Adv. for Mr Satyen Sethi, Adv. RAJIV SHAKDHER, J.: (ORAL) CM Appls.53068-69/2023 [Applications filed on behalf of the appellant/revenue seeking condonation of delay of 5 days in filing and 38 days in re-filing the appeal.] 1. These are the applications moved on behalf of the appellant/revenue, seeking condonation of delay in filing and re-filing....

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....respect is quantified at Rs. 6,34,83,482/-. 9. The record shows that the Assessing Officer (AO) via the order dated 29.12.2008 has disallowed the engineering fees paid by the respondent/assessee to its head office on the ground that the time log sheets were not filed. 10. The Commissioner of Income Tax (Appeals) [in short, 'CIT(A)'] via the order dated 27.06.2013 has sustained the view taken by ....

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....shwini Kumar, who appears on behalf of the appellant/revenue, submits that without relevant evidence, the expenses incurred by the respondent/assessee could not have been allowed towards the engineering fee. 14. We have examined the reasoning furnished by the AO and the CIT(A). 15. We are inclined to agree with the view taken by the Tribunal for the reason that the involvement of the respondent/....