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2023 (8) TMI 1254 - AT - Income TaxDeduction u/s 80IA - AO considered Cargo Services rendered by the assessee company to be not covered for the benefit of Section 80IA - assessee had claimed that maintaining, managing, operating, upgrading, modernizing and developing the cargo terminal at the IGI Airport falls in the definition of infrastructural facility u/s 80IA - CIT(A) has deleted the disallowance - HELD THAT:- As decided in assessee own case [2018 (11) TMI 1322 - ITAT DELHI] appellant has satisfied all the conditions to claim deduction under section 80IA. Addition of miscellaneous expenditure - revenue argued assessee had failed to produce bills and vouchers still Ld. CIT(A) has deleted the addition - HELD THAT:- The order of Ld. CIT(A) indicates that like AO he has also gone on the general observations however he was correct in holding that if an expenditure is to be disallowed then the same needs to be examined ascertaining if the same is wholly and exclusively in the course of business. There being no finding on that aspect with regard to disallowance of expenses, other than miscellaneous expense which certainly required production of bills and vouchers, to examine the head under which they can be considered for being allowed, having been incurred wholly and exclusively in the course of business. As no specific bills and vouchers were filed, at any stage, the miscellaneous expenses was wrongly deleted by Ld. CIT(A) and to that extend the ground no. 2 of the Revenue is allowed partly
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