TMI Blog2020 (2) TMI 544X X X X Extracts X X X X X X X X Extracts X X X X ..... ent activities carried on by the assessee-company during the year under consideration, which is duly taken note of by the Assessing Officer in paragraph no. 2.1 of the assessment order and having regard to the fact that the status of the assessee being a Company, which is required to comply with the statutory requirement, we are of the view that the disallowance of 90% of the expenditure claimed b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dent ORDER Per Shri P.M. Jagtap, Vice-President: This appeal filed by the assessee is directed against the order of ld. Commissioner of Income Tax (Appeals)-12, Kolkata dated 29th March, 2019 and the solitary issue involved therein relates to the disallowance of ₹ 17,55,000/- made by the Assessing Officer on account of salary expenditure, which is sustained by the ld. CIT(A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and bonus to the employees were paid could not be furnished by the assessee. Keeping in view this failure of the assessee to furnish the relevant details and documents and having regard to the fact that the activity of the assessee-company was limited to investment, which had resulted in earning the income on account of interest only to the extent of ₹ 29,79,864/-, the claim of the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... de by him and sustained by the ld. CIT(Appeals) to the extent of 90% is highly excessive and unreasonable keeping in view the fact that the assessee is a Company, which was engaged in the business of investment and the investment made by it in the unlisted equity shares had increased from ₹ 2,83,50,000/- to ₹ 5,07,05,000/- during the year under consideration as noted by the Assessing O ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... T(Appeals) is highly excessive and unreasonable. According to us, it would be fair and reasonable in the facts and circumstances of the case to restrict the disallowance made by the Assessing Officer on account of salary and bonus to 50%. We accordingly modify the impugned order of the ld. CIT(Appeals) on this issue and restrict the disallowance made by the Assessing Officer on account of salary a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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