TMI Blog2020 (10) TMI 83X X X X Extracts X X X X X X X X Extracts X X X X ..... enses were claimed on the basis of self-made vouchers and the assessee could not produce satisfactory evidences in support of the same. Some adhoc disallowance is justified on the facts and circumstances. Keeping in view the assessee s turnover, profits reflected during the year, we restrict the Motor Car disallowance to 20% - adhoc disallowance against unverifiable expenses is estimated @5%. The assessee would be entitled for relief of 25% u/s 80-IB against both the items. AO is directed to recompute the income of the assessee in terms of our above adjudication. The appeal stands partly allowed. - I.T.A. No.2669/Mum/2019 And I.T.A. No.2670/Mum/2019 - - - Dated:- 29-9-2020 - Shri Mahavir Singh, VP And Shri Manoj Kumar Aggarwal, AM ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e hands of appellant in A.Y. 2012-13 as well as in A.Y. 2015-16 and there was no specific reason for making disallowance in current year. 4. Appellant pray that disallowance made be deleted. As evident, the assessee is primarily aggrieved by disallowances of certain expenses. The Ld. AR, Shri Shankar Lal Jain, filed supporting documents and advanced arguments assailing the adhoc disallowances made by lower authorities. The Ld. Sr. DR, Ms. Samatha Mullamudi, drawing attention to the orders of lower authorities, justified the disallowances. We have duly considered the same. 2.1 The material on record would show that an assessment was framed against the assessee u/s. 143(3) on 30/03/2016 wherein the assessee was saddled with adhoc dis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ld. AO estimated an addition of ₹ 10 Lacs against the same. However, Ld. AO provided deduction u/s 80-IB against the same @25%. In nutshell, the assessee was saddled with effective disallowance of ₹ 7.50 Lacs. 2.3 Similarly, discrepancies were found in respect of actual cash found at the premises and cash as per books of accounts. Upon perusal of expenditure details, it transpired that the assessee incurred aggregate expenditure of ₹ 7.98 Lacs on account of labor-welfare expenses and conveyance expenses. The said expenditure was claimed against selfITA made vouchers. Ld. AO estimated disallowance of ₹ 1.60 Lacs against the same. However, the relief of 25% u/s 80-IB was provided against this disallowance also. In ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he items. The Ld.AO is directed to recompute the income of the assessee in terms of our above adjudication. The appeal stands partly allowed. ITA No.2670/Mum/2019 (AY 2014-15) 4. Facts are pari-materia the same in AY 2014-15. The assessee was saddled with adhoc disallowance of ₹ 10 Lacs against Motor Car and another adhoc disallowance of 10% amounting to ₹ 5.08 Lacs on account of conveyance and staff welfare expenses. Since facts are identical, applying the adjudication of AY 2013-14, the Motor Car expenditure disallowance is restricted to 20% of ₹ 26,41,702/- which comes to ₹ 5,28,340/-. The disallowance on account of conveyance expenses staff welfare expenses is estimated @5% which comes to ₹ 2,54 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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