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2023 (5) TMI 319 - HC - Income TaxDeduction u/s 80JJA - discrepancy in the stock - HELD THAT:- While filing return of income in respect of manufacturing items, deduction qua the stock of Hindustan Sanitary Plaza could not be given under Section 80JJA of the Act. Tribunal has rightly rejected the claim of the appellant on this ground as well as on the ground of non-disclosure of the closing stock. Disallowance of expenses - Tribunal has observed that the AO has disallowed 25% of the expenses claimed under the heads consumables, power/fuel, packing, freight, miscellaneous, telephone, conveyance, travelling etc. as no vouchers were produced for expenditure claimed as Rs. 47 lacs. AO had given full opportunity to the assessee, who could submit evidence of expenditure of about Rs. 8 lakhs out of his claim of Rs. 54.92 lakhs. The Tribunal has further held that the disallowance was rightly restricted to 1/10th of the expenditure, which had not been substantiated by the assessee, which comes to about Rs. 4,70,000/-. After going through the impugned judgment, this Court is of the view that in this case, the Tribunal has rightly dismissed the appeal(s) of the assessee by appreciating the evidence in the right perspective. Appellant-assessee has not led any cogent and convincing evidence to prove his case. No substantial question of law arises for consideration in these appeals.
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