Revenue, submitted that the assessee has claimed `4.35 Crores
towards management consultancy fees. The Transfer Pricing
Officer found that the details of specific services provided ... assessee-company
should have received double the amount towards management
consultancy fee from TCM and CMT.
35. We have carefully gone through the provisions
ZPMC,that as per the agreements ZPMC
was required to pay consultancy fees to the assessee towards sale of cranes, that the payment
was made ... conducted technical activities for its group entities,that the
consultancy fees paid by ZPMC to it was in nature of FTS,that the payment
case and in law, ld CIT (A)
erred in allowing the consultancy fees incurred for business process re-
engineering, ignoring the fact that ... dismissed.
24. Ground No.4 relates to deleting the disallowance of consultancy fee for
business process Re-engineering
focuses on consultancy and advisory
which is its core area and competency. The revenue generation is purely from
consultancy fees which is evident from profit ... rendering only advisory and
consultancy services. The whole revenue is again from' consultancy/advisory fees. In
the instant case also the appellant is providing
Income Tax
Act 1961.
(4) CONSULTANCY FEES
That so far as the consultancy fees collected by the Appellant from various
state Govt, organizations is concerned ... Amount (in Rs)
i Training fees 21,26,675=00
ii JLT Fees 2,11,700=00
iii Consultancy charges
focuses on consultancy and
advisory which is its core area and competency. The revenue generation is purely from
consultancy fees which is evident from profit ... rendering only advisory and consultancy services. The whole revenue is
again from' consultancy/advisory fees. In the instant case also the appellant is providing
fact that if machinery cost would
have been capitalized, the associated consultancy fee should also
be capitalized.
4.That the appellant craves to be allowed ... learned Commissioner of Income-tax (Appeals) on the issue of
consultancy fee incurred in relation to plant and machinery.
11.1 The facts in respect
Professional charges.
c) Rs.9,00,000/- under the head 'Consultancy fee'.
2 ITA No.121/Del./2014
The above action being arbitrary ... legal and professional charges of Rs.16,43,000/- and consultancy fee paid
of Rs.9,00,000/-. During the course of scrutiny proceedings
Delhi
dated 09/09/2013 confirming the disallowance consultation fees of Rs. 5507987/-
made by the deputy Commissioner of income tax, Circle ... appeals) has further erred in
observing that the payment of consultancy fee by this assessee was made
without any basis.
7. That the Ld. Commissioner
reason that the
FIRCs contain the nature of remittance as 'consultancy fee from
client' or 'software consultancy free from client ... from the export turnover
treating the same as consultancy fee from client/software consultancy
fee from client, as mentioned in the FIRCs, without considering
