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2017 (10) TMI 1256 - ITAT MUMBAIAddition of bogus purchases and sales promotion expenses - CIT(A) in restricting disallowance of made out sales promotion expenses to 10%, as against the disallowance made by AO @ 100% - Held that:- CIT(A) noticed that the AO did not give any reasoning for disallowing expenses at different rates. Accordingly he restricted the disallowance made out of Sales promotion expenses also at uniform rate of 10% in all the three years under consideration. We notice that the learned CIT(A) has taken this view upon noticing that the Assessing Officer has not furnished any credible reason for disallowing Sales promotion expenses @ 100%, while making disallowance out of advertisement and transport expenses @ 10%. Before us, the revenue could not furnish any valid reason for adopting different standards for making disallowance out of expenses, when the underlying facts are identical in all the cases. Hence we are of the view that the order passed by the learned CIT(A) on this issue also does not call for any interference in all three years under consideration. - Decided against revenue.
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