Remuneration paid to Management Graduates related to business is allowable

M/s. Hinduja Group India Ltd. Vs ACIT (ITAT Mumbai) We observe that in the case at hand, payment is made to the employees who are unrelated third parties and no payment has been made to the group companies or related parties, hence provisions of section 40A(2) are not applicable. Further even section 40A(2) provides for disallowance of excessive payments made to Group Companies and there is no provision in the Act for disallowance of under charging of fees. The observations of the AO and CIT(A) that no evidence were submitted as regards which employees were sent on deputation and to which comp...