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2021 (9) TMI 847 - AT - Income TaxRevision u/s 263 by CIT - AO failure in not examining the taxpayers sale promotion expenses - AO disallowed 12% of the assessee’s sale promotion expenses - HELD THAT:- CIT-DR fails to dispute that the Assessing Officer had very much disallowed 12% of the assessee’s sale promotion expenses and therefore, it is not an instance of lack of inquiry as has been projected in the revision under challenge. AO directing the assessee to produce bills and vouchers relating to the impugned expenses and on examining the same finding them as being not completely verifiable. AO states that the assessee was unable to produce the bills /vouchers for the expenses so debited, and he further notes that the assessee expressed his inability to produce any further documentary evidences. Faced with these facts the AO proceeds to make an adhoc disallowance of 12% of the expenses. It is abundantly clear therefore that it cannot be said to be a case of no inquiry. Further no case has been made out by the Ld.CIT of inadequacy of inquiry conducted by the AO on the issue. Appeal of the assessee is allowed.
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