DCIT v. Barclays Global Services Centre (P.) Ltd. (2021) 191 ITD 84 / 89 ITR 40 (SN) (Pune)(Trib.)

S. 251 : Appeal-Commissioner (Appeals)-Powers-Amounts not deductible-Deduction at source-Non-resident-Reimbursement of expenses- Cost of allocation-Not passed reasoned order-Matter remanded to CIT(A). [S. 9(1)(vii), 40(a)(i), 195, 250, 254(1)]

Held that since no reasons were recorded by Commissioner (Appeals) in support of his finding in deleting disallowance made by Assessing Officer under section 40(a)(i) of the Act. Matter remanded to file of CIT (A) for fresh adjudication.  (AY. 2009-10)