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2022 (12) TMI 392 - AT - Income TaxRevision u/s 263 - additions made by the A.O. as commission received after allowing 50% expenses against the impugned commission - HELD THAT:- We are of the considered opinion that the assessee even during the second round of litigation has failed to substantiate its claim for allowing 95% of the expenses alleged to be incurred in earning the commission income received by the assessee from MSEDCL. The assessee neither before us, nor before the lower authorities have filed any additional evidences pertaining to its claim. We are of the considered view that the assessee has been given sufficient relief by the lower authorities in allowing 50% of the expenses claimed by the assessee in earning the impugned commission received from MSEDCL. Assessee has failed to prove that the said expenses were incurred wholly and exclusively for the purpose of earning the commission income. Sale of loan application form - As observed that the assessee has failed to furnish relevant details pertaining to the expenses claimed by the assessee for the above mentioned heads. Even during the second round of litigation, the assessee has not submitted any additional evidences pertaining to the said claim either before us or before the lower authorities. Interest on deposit on security from MSEDCL - AR submitted that similar receipts were derived by the assessee society in A.Y. 2008-09 and no addition was made for the same by the A.O. thereon. In view of this, we deem it fit and appropriate, as a last and final opportunity, to remand this issue to the file of the A.O. Miscellaneous Receipt, Recovery Expenses AND Interest on loan to staff & interest on employees housing loan - AR submitted that similar receipts were derived by the assessee society in A.Y. 2008-09 and no addition was made for the same by the A.O. thereon. In view of this, we deem it fit and appropriate, as a last and final opportunity, to remand this issue to the file of the ld. A.O.
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