Assessee made payments to Bank and rental payments made to Customer Assets India P Ltd. AO  held that  these two entities did not have any written agreement for sharing of facilities and since Bank was related to assessee, AO disallowed 50% of said expenses by invoking provisions 40A(2)(a) of the Act which  was  confirmed  by CIT (A). Tribunal held that  both are  paying same rate of taxes hence no disallowances can be made.  Referred  Indo Saudi Services (Travel) P Ltd.  AO should also consider claim of assessee that amount disallowed would be eligible for deduction u/s. 10A, if he was not satisfied with original claim.  AO also disallowed 20% of rent paid to sister concern which was confirmed by CIT(A). Tribunal held that, If AO was satisfied that there was no excess payment, then no disallowance out of rental expenditure was called for. Matter remanded. Followed CIT v. Indo Saudi Services (Travel) P. Ltd. (2009) 310 ITR 306 (Bom.)(HC)  (AY. 2004-05, 2005 -06)