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2012 (9) TMI 788 - AT - Income TaxAd-hoc addition on account of variation in the yield and higher wastage in comparison to previous years Assessee was engage in business of manufacturing and trading of Printed Circuit Boards Products are manufactured as per specification of customers - Held that:- As the generation of wastage on cutting of large copper clad laminates into smaller pieces of PCBs which are of different sizes as per the requirements of the customers. The manufacturing process involves some wastage and no addition was made in the past on account of such low yield and also the addition has been made by AO on the basis of presumptions. Appeal decides in favour of assessee. Ad-hoc disallowance on account of carriage inward/outward AO found that some of these expenses are not fully supported with proper evidences - Vouchers since certain vouchers are of self-made Held that:- Since neither the details in respect of carriage inward/outward was submitted nor any evidence was produced or claim made about the genuinuity of self-made vouchers questioned by the Assessing Officer could not be controverted by the assessee. Restrict the disallowance upto 50% of disallowed amount. Addition on account of Bad debts AO disallow the same on the basis of that the assessee had not taken any steps to recover the bad debts Held that:- As the assessee submitted that these are really not bad debts but various outstandings on account of sales which should have been reversed. Issue remand back to AO. Disallowance on account of stipend to trainees - Training was given at the factory premises by the Senior Member of the factory - AO noted that no statistical data, no dates of training, no agenda of the training, no venue of the training are submitted Held that:- As concluded from the facts of the case addition made by the AO on the ground that such huge expenditure under the head stipend does not look justified. Merely because the disallowance is a small percentage of the total expenditure cannot be a ground for sustaining the addition. If the claim is bogus, the entire amount has to be disallowed and if not bogus the whole amount should be allowed as deduction but no adhoc addition can be made on the basis of presumptions and surmises. Therefore disallowance of stipend is not justified. Decision in favour of assessee
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