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2021 (7) TMI 52 - AT - Income TaxDisallowance being 20% of total travelling expenses - as argued these expenses have been incurred on tour and traveling of officers and employees of the company and the purpose of travel was meeting prospective buyers, sellers, visits to difference sites and prospective markets etc. - CIT-A deleted the addition - HELD THAT:- DR has not brought on record any justifiable reason requiring any interference with the conclusions recorded by the Ld CIT (A) in the impugned order on this issue. As noted above, the assessee has filed requisite details of travel expenses not only before the AO but also before Ld. CIT (A). We find no merit in the case of the AO for making an ad hoc disallowance @ 20%. The AO has not even highlighted or pointed out any deficiency in the details submitted by the assessee. Considering this, we find no reason to interfere in the conclusions recorded by the Ld. CIT (A). Grounds 1 & 2 are hence dismissed. Disallowance of interest expenses - expense on loan taken from its 100% Holding Company - CIT-A deleted the addition - HELD THAT:- We find no merit in the observations of the AO that the assessee has not carried out its business of real estate and infrastructure development during the year under consideration. - DR has not been able to demolish the facts recorded by Ld. CIT (A) wherein it is noted that during the year under consideration, the assessee had made various efforts to enter into business activities. It had undertaken more than 9 projects and also carried inventory of 53.87 crores of traded goods in the form of apartments which was ready for sale and which were also sold subsequently in the future years. The assessee had also participated in joint venture projects outside India. These activities of the assessee were in consonance with its Memorandum of Association. During the year under consideration, the assessee had made fresh borrowings from its holding company. The assessee had submitted details of utilization of this sum which is on record and noted by the Ld CIT (A) - Once these details are perused, the obvious conclusion is that there is a clear connection between the money borrowed and its utilization for purposes of business of real estate and infrastructural development carried on by the assessee. We, therefore, find no merit in the disallowance made by the AO and the impugned order is therefore upheld. Ground No.3 is, therefore, dismissed.
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