Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2017 (6) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (6) TMI 1312 - AT - Income TaxDisallowance as lorry hire charges - production of self vouchers and PAN - proof of reasonable probability - HELD THAT:- Sum shown by the assessee as lorry hire charges payable and it appeared in its balance sheet as ‘’ freight payable’’. It is mentioned by AO in the remand report the such amounts were, even as per the assessee cleared only in April, 2014, which is more than two years after the end of the relevant previous year. Since the amount was represented by 117 entries all of which were below ₹ 20,000/-, it is clear that the concerned parties, if at all they were there, were all small business persons. To presume that such small business people would have waited for more than 24 months for getting their payments is beyond preponderance of probability. Assessee was having a net profit of ₹ 19,39,154/- for the relevant previous year and a turnover of ₹ 9,46,63,745/-. Hence, there was no reason to postpone he payment to small parties for a period of 24 months. In my opinion, mere production of self vouchers and PAN will not be sufficient to believe an expenditure, which otherwise show by itself as quite against all reasonable probability. In such circumstances,lower authorities had every reason to disbelieve the claim and make the disallowance. - Decided against assessee.
|