TMI Blog2021 (6) TMI 526X X X X Extracts X X X X X X X X Extracts X X X X ..... o be made as it is a revenue neutral instance only. We adopt the same reasoning herein as well and direct the Assessing Officer to delete the impugned disallowance. The assessee s former substantive ground is accepted therefore. Employees provident fund disallowance u/s 36(1)(va) - HELD THAT:- The assessee s only case as per its computation is that it had suo motu disallowed the very expenditure in the corresponding computation which renders it as an instance of double addition of the claim.. We direct the Assessing Officer to delete the same therefore. - I.T.A. No. 2090/HYD/2018 (Assessment Year: 2014-15) - - - Dated:- 11-5-2021 - SHRI S.S.GODARA, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER For Assessee : S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wards prior period expenses which was incurred by the appellant during the course of its business. However, the Assessing Officer has disallowed the said expenses stating the same to be not allowable as the same 'were incurred in previous years and not in the current year. In this regard it is submitted that, the appellant has incurred an expenditure of ₹ 47,50,000/- which was crystallised in the present assessment year and hence the appellant has accordingly claimed deduction u/s. 37(1) of the Act. Further, it is submitted that the said expenditure is incurred by the appellant 'wholly and exclusively for the purpose of business. The said expenditure of ₹ 47,50,000/- was incurred for functioning of its operations a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed as deduction u/s. 37 of the Act. In the present case, the appellant company has incurred an expenditure of ₹ 47,50,000/- which was crystallized in the year under consideration and was incurred wholly and exclusively for the purpose of business. As the said expenditure of ₹ 47,50,000/- was laid out wholly and exclusively for the purpose of business, the same is eligible to be claimed as deduction u/s 37(1) of the Act and accordingly claimed by the assessee. In view of the facts and circumstances submitted above, it is requested before the Han. Commissioner of Income Tax (Appeals) to kindly delete the disallowance of ₹ 47,50,000/- made by the Assessing Officer for the year under consideration . 7.3 I have care ..... X X X X Extracts X X X X X X X X Extracts X X X X
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