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Tribunal Overturns Arbitrary Disallowance of 50% Back Office Charges, Citing Acknowledged Benefits to Assessee.
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....Disallowance u/s. 40A(2) - addition being 50% of the total back office charges paid to group consultant - The Tribunal held that, AO has observed that the assessee may have benefitted from the bulk or centralized purchasing done though to group consultant but it does not justify the entire payment. Once it is accepted by the AO that the assessee is benefited through to group consultant , no adhoc disallowance is called for - we delete the disallowance u/s. 40A(2) of the Act.....