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2022 (9) TMI 1484 - AT - Income TaxDisallow 10% of the expenses excluding the commission expenses - HELD THAT:- CIT(A) is of the opinion that no disallowance out of commission expenses on ad-hoc basis is called for. Further, in so far as, other expenses concerned, which are incurred partly in cash, therefore, the same are not fully verifiable. Accordingly, the Ld.CIT(A) has directed to disallow 10% of the expenses excluding the commission expenses. Neither the A.O nor the CIT(A) have discussed the details of the expenses and how the assessee has failed to prove the genuineness of the expenses, but proceeded to disallow the expenses without pointing out the defects in the accounts of the assessee. Therefore, in our opinion, the entire approaches of the Lower Authorities are erroneous. Accordingly, the disallowance sustained by the CIT(A) is hereby deleted. Decided in favour of assessee.
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