The Assessing Officer held  the assessee company could not show that there was in fact receipt of services, the payment commensurate with the benefit and such payments benefited the assessee directly and tangibly  therefore determined the arm’s-length price of the international transaction at nil and added the sum of Rs.7,05,54,285/-to the income of the assessee. CITT (A) deleted the addition . On appeal by revenue   the Tribunal held that the findings of the Assessing Officer that the payments were made without any business purpose and without any commensurate benefit to the assessee are not based on any cogent material and without bringing any adverse material on record. The very fact of the Assessing Officer disallowing the income and the reimbursement which does not pass through the P&L account while disallowing the expenses shows that the disallowance was made by the learned Assessing Officer without any proper verification of the material facts available on record. Order of the CIT (A) is affirmed .  (AY. 2011-12 )