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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Rahul Chaudhary, Judicial Member, Makarand Vasant Mahadeokar, Accountant Member
Dentsu Aegis Network India Private Limited – Appellant
Versus
DCIT Central Circle-1(1) – Respondent
| Table of Content |
|---|
| 1. facts of salary recharge disallowance under s.37(1) & 40a(2)(b) (Para 2 , 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11 , 12 , 13 , 14) |
| 2. assessee's arguments on genuine reimbursements, no excessiveness (Para 15 , 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24) |
| 3. revenue's stand and lower authorities' confirmation (Para 25 , 26 , 27 , 28 , 29) |
| 4. s.40a(2) requires excessiveness finding; shared services allowable (Para 30 , 31 , 32 , 33 , 34 , 35 , 36) |
| 5. disallowance deleted; appeal allowed (Para 37 , 38 , 39) |
आदेश/ORDER
PER MAKARAND VASANT MAHADEOKAR, AM:
This appeal is directed against the order dated 31.07.2025 passed by the Commissioner of Income-tax (Appeals)–47, Mumbai [hereinafter referred to as “CIT(A)”] under section 250 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”]arising out of the assessment order dated 07.12.2016 passed by the Assessing Officer under section 143(3) of the Act for the Assessment Year 2014–15.
2. The brief facts of the case are that the assessee, formerly known as M/s. Vizeum Media Services India Private Limited and now merged with Dentsu Aegis Network India Private Limited, is engaged in the business of media services, including media con
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