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2023 (6) TMI 341 - ITAT MUMBAIAllowable Business/revenue expenses - directors education expenses - whether are wholly and exclusively incurred for the purpose of business? - assessee is a company and is engaged in the business as importer and exporter of bearings and components - HELD THAT:- The assessee is not involved in any manufacturing activity. There is no material available on record that the assessee has any presence outside India. Director was claimed to be already a graduate in management at the time of his appointment as Director of the assessee company. Therefore, when the assessee’s business is merely in the nature of a trader with no presence outside India and its Director was already a graduate in management, no sufficient basis has been brought on record to show how the financial support provided by the assessee to its Director to pursue MSc in International Business Management is wholly and exclusively for the assessee’s business purpose and has a direct relationship with the assessee’s business activity. Since, in the present case, the assessee has failed to substantiate that the expenditure was incurred wholly and exclusively for the purpose of business, therefore, we find no infirmity in the impugned order affirming the disallowance of the Director’s education expenditure u/s 37(1) - Appeal by the assessee is dismissed.
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