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2019 (10) TMI 1521 - AT - Income TaxDisallowance on account of Sales Promotion and disallowance on account of cost of goods for free replacement - Disallowance on account of discount to Indian customers - non-furnishing of the requisite documentary evidence - assessee contended that all the necessary documents qua allowances claimed have been produced before the AO - HELD THAT:- Undisputedly, the AO has disallowed all the aforesaid expenses on ad hoc basis. It is also not in dispute that neither in the preceding years nor in the succeeding years, such expenses claimed by the assessee have been disallowed by the Revenue. AO as well as CIT (A) have time and again mentioned in the order that the additions are being made on account of non-furnishing of the requisite documentary evidence to substantiate the sale promotion, goods replaced and discount given to the Indian customers. For perusal of the Bench, assessee produced plethora of documents to support his contention. We are of the considered view that when the assessee has produced requisite documentary evidence before the AO, the addition was not required to be made on the ad hoc basis rather it should have been made, if any, on the basis of actual facts of the case. In these circumstances, we deem it necessary to remand the case back to the AO to decide afresh in the light of the documents relied upon by the assessee as well as in the light of the facts that such allowances claimed by the assessee have been allowed by the Revenue itself in the preceding as well as succeeding years. Appeal filed by the assessee is allowed for statistical purposes.
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