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2022 (8) TMI 909 - AT - Income TaxDisallowance of Finance Cost - CIT-A held that appellant could not prove the nexus between the Sundry Debtors and Long Term Advances as per accounts and thereby confirming disallowance of Finance Cost - HELD THAT:- By referring to the audited financial statements as pointed out by the Ld. Counsel, we find force in the submission and explanation given by him. In the course of hearing, a chart has been submitted explaining the long term borrowing utilization which very clearly depicts the treatment of the long term borrowing and its utilization. Thus with all its proper reporting and disclosure, we are inclined to accept the submissions of the Ld. Counsel and direct the Ld. AO to delete the addition made - Accordingly, the grounds of appeal in this respect are allowed. Disallowance of sales promotion and advertisement expenses - HELD THAT:- Despite several queries and opportunities made available by the authorities below, the assessee has not been able to establish the nexus between the expenses incurred and the business of the assessee. Assessee has all along submitted only the ledger account copy, which are not sufficient to understand the nature and the purpose of expenses incurred as well as its nexus with the benefits accruing to the business of the assessee - we find it proper to remit the matter back to the file of Ld. AO on this issue and direct the assessee to submit necessary documentary evidences required by the authorities below for substantiating its claim for the deductibility of the expenses. Accordingly, this ground of appeal is allowed for statistical purposes. Disallowance being depreciation on Motor Car inspite of Purchase Bills, Bank loan for car, Tax Token and other evidences - Assessee has claimed that all the payments in respect of purchase of motor cars have been made through banking channel. In the interest of justice and fair play, we find it proper to remit the matter back to the file of Ld. AO and direct the assessee to furnish all the required documents towards the purchase of motor cars as reported in its audited financial statements on which depreciation has been claimed. Ld. AO is also directed to provide reasonable opportunity of being heard in this respect so as to enable the assessee to substantiate its claim. Accordingly, this ground of appeal is allowed for statistical purposes. Appeal of the assessee is partly allowed.
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