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2022 (8) TMI 854 - AT - Income TaxAddition u/s 68 - non-confirmation of credit balances payable as provision for internal audit to TR Chadha and Co. and sum payable as leave and pension contribution to deputationist Ms. P Meera Anusha who came from State Govt. as undisclosed credit balances - HELD THAT:- Contention of the assessee that the amount was made as a provision entry for F.Y. 2015-16 relevant to A.Y. 2016-17 towards internal audit fees payment to M/s. T. R. Chadha & Co., who the internal auditors of the company. Since M/s. T. R. Chadha & Co. has raised invoice in subsequent Financial Year i.e. in F.Y. 2016-17 after the completion of work, it was not reflected in their confirmation. Assessee has also produced the copy of account which evidences the payment of Rs. 99,000/- made to M/s. T. R. Chadha & Co. in subsequent financial year aforesaid contention of the assessee has not been controverted by Revenue. Considering the totality of the aforesaid facts, we are of the view that no addition was called for more so, when no evidence about the expenses being bogus in nature has been brought on record by the Revenue. We, therefore, direct the deletion of addition made by AO. Addition payable to M/s. P. Meera Anusha, it is the contention of the assessee that she is an employee of State Govt. on deputation to the company and as per the understanding with State Govt., assessee is required to pay her in addition to her salary, the leave and pension contribution and reimbursement of expenses like Telephone, newspaper etc. The assessee has also placed on record the copy of the claims towards the expenses and the leave and pension contribution made by the assessee through her parent organization. Assessee has also demonstrated that the aforesaid amount has been paid to the assessee in subsequent year - Thus in the absence of the any evidence placed by the Revenue to demonstrate that the payment is bogus in nature, we are of the view that no disallowance of aforesaid expenses is called for in the present case. We, therefore, direct its deletion thus the ground of assessee is allowed.
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