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2021 (5) TMI 204 - AT - Income TaxAddition towards office rent and office maintenance charges - apportionment of expenses to the sister concerns and group companies - CIT(A) partially sustained the addition by estimating the disallowance @ 50% of the total expenditure incurred towards rent paid for office premises and office maintenance expenses - HELD THAT:- Submissions of AR on that regard could not be successfully controverted by the Ld. Revenue Authorities either with any material evidence or from the books of account of the assessee company or from the particulars of the assessee's subsidiary companies. Therefore, it appears that all the subsidiary companies of the assessee are only existing on paper and not conducting any significant activities. CIT(A) has also not brought out any categorical finding to controvert the same in his Order. When all the assessee's sister companies are only paper companies with no activities conducted during the relevant assessment year it is obvious that the entire expenses incurred towards office rent and office maintenance charges are attributable to the assessee company and therefore these expenses cannot be apportioned to the assessee's sister companies and if at all apportionable it would be negligible. No merit in the addition made and sustained by the Ld. Revenue Authorities in the hands of the assessee company by disallowing the portion of expenditure incurred by the assessee company towards rent of office premises and office maintenance charges. Hence, We hereby direct the Ld. A.O. to allow the entire amount as allowable deduction - Decided in favour of assessee.
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