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| The Tax Publishers2021 TaxPub(DT) 0682 (Del-Trib) : (2021) 086 ITR (Trib) 0121 INCOME TAX ACT, 1961
Section 37(1)
By becoming part of global net work of professional firms, it was easier to get work of international clients who were referred by firms of other companies from other countries. Similarly, assessee could also refer its clients to its associated firm in other countries where clients could require professional services. The use of name 'Delotte' is in itself sufficient to justify business necessity of subscription charges. Therefore, AO was not justified to make disallowance.
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Business expenditure - Subscription fees paid to Deloitte Touche Tohmatsu (DTT) - Allowability -
Assessee claimed deduction of subscription fees paid to Deloitte Touche Tohmatsu (DTT). AO took the view that subscription fee was not wholly and exclusively for the purpose of business/profession and thus disallowed entire amount of subscription fee paid. Held: By becoming part of global net work of professional firms, it was easier to get work of international clients who were referred by firms of other companies from other countries. Similarly, assessee could also refer its clients to its associated firm in other countries where clients could require professional services. The use of name 'Delotte' is in itself sufficient to justify business necessity of subscription charges. Therefore, AO was not justified to make disallowance.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 37(1)
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