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2019 (11) TMI 512 - ITAT DELHIDisallowance of expenses - no business activity was conducted during the year under consideration and the assessee company has not furnished any substantial evidence to show that the travel expenses were actually incurred for travelling made for business purposes - HELD THAT:- Since the assessee in the instant case has started deploying the skillful personnel and has covered the last mile of its preparedness on 07.07.2008 when the sales head Shri Sanjay Sharma was appointed, therefore, we do not find any infirmity in the order of the CIT(A) in holding that the assessee has set up its business on 07.07.2008 and, therefore, is entitled to claim the expenses as a revenue expenditure for the period from 07.07.2008 till 31.03.2009 subject to verification of the details by the AO. The submission the assessee has earned income of ₹ 17.14 million in the subsequent F.Y. 2009-10 could not be controverted by the ld. DR. No infirmity in the order of the CIT(A) in holding that the assessee has started its business operation on the date of recruitment of sales head on 07.07.2008 and directing the AO to obtain the details of expenses of ₹ 8,66,73,393/- out of the expenses disallowed of ₹ 10,28,95,398/- pertaining to the period from 07.07.2008 till 31.03.2009 and allow the same as deduction in the year under consideration. The grounds raised by the Revenue are accordingly dismissed.
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