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2023 (4) TMI 1156 - AT - Income TaxDisallowance of expenses on ad-hoc basis - HELD THAT:- Neither the lower tax authorities pointing out any such vouchers, the genuineness of expenditure therein claim to have been incurred by the wholly and exclusively for the purpose of its business did not provide any sustainability to the orders of the authorities below. It was not the case of revenue that any part of expenditure in question was not either found to be bogus or fictitious nor was found to have not been incurred by the assessee wholly and exclusively for the purpose of his business. In the present case the assessee has successfully demonstrated that his turnover during relevant financial period was more and the quantum of disallowance is very small in comparison to the turnover. Therefore when the assessee has successfully demonstrated that the expense has been incurred wholly and exclusively for the purpose of business of assessee and the AO has not point out any specific defect or deficiency therein then the disallowance cannot be made on ad-hoc basis without any specific allegation merely on the basis of general remarks and observations - See SHRI KAILAS CHAND AGRAWAL case [2022 (4) TMI 671 - ITAT RAIPUR] as followed - Decided in favour of assessee.
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