Amalgamations Valeo Clutch Private Limited Vs DCIT (ITAT Chennai)
ITAT Chennai held that no findings have been rendered on various documentary evidences furnished by the assessee. Accordingly, matter restored in view of violation of the principle of natural justice.
Facts- The assessee claimed expenditure of Rs.93.70 Lacs as shared service center cost (SSC). The same was as per the agreement entered into by the assessee with M/s Valeo India Private Limited (VIPL). As per the terms of the agreement, the assessee sought to avail services in the area of finance, purchase, quality, logistic, human resources and information systems etc. As per assessee’s submissions, VIPL had assisted in various activities. However, the submissions were not acceptable.
AO cited the example of legal and professional expenses which was claimed for Rs.72.68 Lacs which was more than the expenditure incurred in earlier years. Therefore, it was held that the services were not supported by any documentary evidence.
Conclusion- Held that though the assessee has furnished various documentary evidences, no findings have been rendered therein and it has been alleged that the services were generalized in nature and the assessee could not establish rendering of services. Therefore, we restore this issue back to the file of Ld. AO for de novo adjudication in the light of aforesaid submissions.
