TMI Blog2018 (10) TMI 1306X X X X Extracts X X X X X X X X Extracts X X X X ..... 9-10. The Revenue has filed the appeal contending that 100% dis-allowance has to be made in all instances. We do not think that the appeal can be sustained especially since the Assessing Officer himself had in certain instances granted 50% dis-allowance. The Tribunal also noticed the fact that, for the next year, the AO had disallowed only 20% of the expenses claimed. The very same procedure was a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... travel of the staff of the assessee company claimed under Section 37 of the Income Tax Act, 1956 (for brevity the IT Act only). 2. The Assessing Officer, for the year 2008-09, disallowed 100% of the expenses and in certain cases found the foreign travel to be partly business and partly personal and allowed 50% of the allowances claimed. In the year 2009-10, the Assessing officer resorted to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... judgment of the earlier Bench of equal strength on the ground that the facts differ from year to year. It was also noticed that the Assessing Officer has given reasons insofar as the dis-allowance for the present years. In any event, orders of the Tribunal for the years 2005-06 and 2006-07 were set aside by us in ITA Nos.285/2010, 335/2010 164/2012. We in the said decision, confined it to the al ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 50% and 100% in various instances of the expenses claimed. The First Appellate Authority had allowed the claim in toto . The Tribunal while considering the appeal of the revenue confined the dis-allowance to 20% as has been done in the year 2009-10. The Revenue has filed the appeal contending that 100% dis-allowance has to be made in all instances. We do not think that the appeal can be m sustai ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
