TMI Blog2015 (11) TMI 10X X X X Extracts X X X X X X X X Extracts X X X X ..... Held that:- Assessee has failed to discharge its onus in furnishing evidences in support of the cash expenses amounting to ₹ 2.01 Crs (rounded-of). We also find similar expenses were incurred in all the AYs commencing from AY 2007-08 to 2012-13 and the amount of expenses incurred vary from ₹ 2.2 Crs to ₹ 1.3 Crs in respect of the assessment years. It is also noticed that the Revenue did not make disallowance in some years and made disallowance of ₹ 5 laksh in AY 2011-2012 and ₹ 1 lakh in AY 2012-2013. It is also in the year under consideration, AO resorted to disallow 25% of the total claim and made huge addition of ₹ 50.42 lakhs. Considering the above facts, we are of the opinion that such % based ad-hoc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee fairly mentioned that the relevant bills / invoices were raised after the end of the previous year. On the other hand, Ld DR relied on the orders of the Revenue Authorities. 3. After hearing both the parties, we find para 2.3 of the CIT (A)'s order is relevant in this regard. In the said para, it is discussed that the said prior period expenses are not allowable considering the system of accounting followed by the assessee. It is not the case of the assessee that the payability is crystallized during the year under consideration. After considering the facts narrated by the Ld Counsel for the assessee as well as the relevant material placed before us, we are of the opinion, the conclusion drawn by the CIT (A) in this regard ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee is in this line of business for many years and the disallowance of this magnitude is done only in the year under consideration. Mentioning that certain ad-hoc additions of ₹ 1 lakh and ₹ 1.5 lakhs was made in the AYs 2011-12 and 2012-13 respectively. Further, he mentioned that no disallowance was made in the scrutiny assessment for the AY 2010-2011. Ld Counsel for the assessee fairly submitted that proportionate ad-hoc disallowance may be made in this year also as the disallowance @ 25% is extremely in higher side. Further, Ld Counsel for the assessee submitted that assessee is consistently reporting the turnover running into crores and the expenditure of ₹ 2,01,68,744/- is required to for registering the turnov ..... X X X X Extracts X X X X X X X X Extracts X X X X
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