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TMI Blog2017 (12) TMI 1624X X X X Extracts X X X X X X X X Extracts X X X X ..... R PER K.N.CHARY, JM Aggrieved by the order dated 28.07.2016 in Appeal No.139/CIT(A)(C)/GGN/2014-15 passed by the Ld. Commissioner of Income Tax (Appeal) [in short "CIT(A)"]-3, Gurgaon for the AY 2012-13, the assessee filed this appeal on various ground. 2. Briefly stated facts are that for the assessment year 2012-13, the assessee filed their return of income on 30/09/2012 and during the scru ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng the same as for non-business purposes, whereas Ld CIT(A) also observed that even during the appellate proceedings the assessee has not denied that part of the expenses claimed under the heading business promotion expenses were not wholly and exclusively for business purpose. Ld. AR brought to our notice that, by way of letter dated 26/09/2014 addressed to the Ld. AO, the assessee stated that,- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eminar/customer lunch and dinner expenses/others 73,95,685 2 Diwali expenses/occasional monuments and gifts 30,26,829 3 New Year retirees and others 2,480 total 1,04,24,994 4. Basing on this, the Ld. AR submits that there is no truth in the observations of the authorities below that the assessee never stated that the entire expenditure was not for business purposes. Ld. AR submit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . AO and for that matter Ld. CIT(A) made the ad hoc disallowance, there does not appear to be any basis for the same. It is not in dispute that vide letter dated 26/09/2014 the assessee has always been maintaining that expenses are purely and comprehensively further business purpose. There is no dispute that any of these expenses are not for business purpose. It is not the case of the Revenue that ..... X X X X Extracts X X X X X X X X Extracts X X X X
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