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2021 (5) TMI 471 - AT - Income TaxUndisclosed overseas deposits - Disallowance of corresponding business expenditure @70% - initiation of Section 153A proceedings - HELD THAT:- Neither the assessee has been able to substantiate all the corresponding expenses incurred abroad as wholly and exclusively for his preaching activity business nor the Assessing authority as well as the CIT(A) have taken any basis for the impugned estimation @30% only. We keep in mind all these peculiar facts and circumstances more particularly the fact that such religion congregations indeed involve day to day running expenses and hold that a lumpsum disallowance of 50% of the expenses in all these assessment years would meet the ends of justice (including 30% already made) with a rider that the same shall not be treated as a precedent in other case. AO is directed to allow 50% of the assessee’s expenses claimed in consequential computation as per law within three effective opportunities of hearing therefore. Disallowance of overseas payment made to Shri Aashish Thomas in the nature of AED 36501 - We notice from a perusal of the corresponding assessment order dt.17-03-2016 that the assessee failed to substantiate the same as running business expenditure which has already been allowed @50%. We thus confirm the impugned payment disallowance
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