TMI Blog2020 (8) TMI 468X X X X Extracts X X X X X X X X Extracts X X X X ..... payment was mere reimbursement of expenditure by M/s PHL. CIT(A) proceeded on wrong footing that the same would be personal expenditure and hence, disallowable completely overlooking the fact that the said expenditure has never been claimed by the assessee anywhere while computing his income. The said expenditure was booked as business expenditure by M/s PHL. Therefore, the impugned additions coul ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ; 1,21, 201/- (made by the Assessing Officer as Deemed Dividend) as the personal expenses of the appellant incurred by the Company disregarding the fact that the same were reimbursements received by the appellant from the company for expenses incurred by the appellant for and on behalf of the company which expenses were for the benefit of the company and not in the nature of personal expenses of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ation to issue raised in the appeal would be as given in succeeding paragraphs. 3. Facts on record would reveal that the assessee being resident individual was assessed for year under consideration u/s 143(3) on 28/11/2016 wherein it was saddled with addition of deemed dividend u/s 2(22)(e) for ₹ 1.21 Lacs. The reason to make the stated addition was the fact that the assessee held 22% sha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... any. These expenses were incurred for and on account of the company and were on account of renewal of membership of the Entrepreneurs organization, USA, covering case for Apple Ipad provided by the company to the assessee for official use and Matrix Card for international roaming mobile expenses during foreign travel for professional work. Therefore, it was submitted that the provisions of Sec. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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