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2014 (4) TMI 437 - AT - Income TaxDisallowance of various expenses – Held that:- All the relevant details asked for by the AO were duly produced before the assessment - It is unjustified on the part of AO that conclusive evidence or complete evidence was not produced - The AO is obliged to give the nature of non-compliance made by the assessee vis-a-vis what is filed by the assessee - A sweeping statement cannot be given that the assessee failed to file conclusive evidence or proper evidence as such observation becomes non-specific having no objective basis – CIT(A) observed that the assessee has made due compliance before the AO - When the compliance is made and is not considered by the Assessing Officer, it cannot be held as fault on the part of the assessee - CIT(A) rightly appreciated the situation and granted partial relief –Decided against Revenue. High ad-hoc disallowance – Held that:- The AO has failed to act in a judicious and objective manner to point out the exact nature of non-compliance and its effect on expenditure - he has substantially disallowed the expenditure on ad hoc basis - there is no justification in such disallowance – thus, there is no justification in again retaining small disallowance on ad hoc basis without giving any reason - there is no justification to retain any disallowance of expenditure made by the assessee without any objective finding about the disallowability - The assessee’s books of accounts are audited and not rejected - the AO in the first part of the order has mentioned about the assessee’s provision of all necessary details – Decided in favour of Assessee.
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