Where assessee, a foundation, engaged in running an educational school, made annual payments under various heads like evaluation fees, authorization fees, fees etc. to various foreign educational institutions and had not offered any explanation regarding basis for raising invoice on assessee and also on what basis discount was offered to assessee even after affording several opportunities to assessee both during course of assessment as well as appellate proceedings, matter was to be remanded to Assessing Officer to understand basis on which lump sum fee was charged by overseas entities from assessee and also basis for allowing/affording discount to assessee – International Education & Research Foundation v. Deputy Commissioner of Income Tax (IT)-1 – [2024] 160 taxmann.com 454 (Ahmedabad – Trib.)
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