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2014 (7) TMI 1301 - AT - Income TaxUnverifiable expenses - addition of 25% on adhoc basis - CIT-A deleted the addition - HELD THAT:- Expenditure has been incurred by India Infoline Ltd on day today basis. It is also an undisputed fact that there exists no agreement for share of the expenditures between India Infoline Ltd and the assessee. It is also an admitted fact that the allocation has been made on adhoc/estimated basis. There is nothing on record to show how many persons were employed by India Infoline Ltd. for the purpose of the business of the assessee. No detail relating to the brokerage and commission has been brought on record. The names of the persons to whom such brokerage /commission has been paid for the business of the assessee. In the absence of specific details, the AO was left with no choice but to make adhoc disallowance of the expenditure. CIT(A) deleted the addition as in his opinion, there was no loss to the Revenue. We do not find any justification in this findings of the CIT(A) as the issue before him was whether the expenditure claimed by the assessee are reasonable and sufficient for its business. The findings of the Ld. CIT(A) is accordingly erroneous since India Infoline has allocated the expenditure on estimated basis, we do not find any error in the findings of the AO who disallowed the expenditure on adhoc basis. - Decided in favour of revenue
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