Disallowance by CIT(A) of expense without any specific opportunity to the assessee in the matter of rendering of services not justified

Optsoe Consultant Private Limited Vs. ITO (ITAT Mumbai)- The dispute is regarding allow ability of expenditure amounting to Rs. 40,20,822/- on account of payments made to the directors as sub-contract charges. The assessee co had been incorporated for undertaking contracts for providing various liaisoning activities in the telecom sector. It had entered into a contract with Chinese company, M/s. ZTE Corporation for providing such services as per which it had received contract charges of Rs. 41,18,969/-. The assessee had sub contracted various services to be provided to its two directors to who...