TMI Blog2021 (7) TMI 1099X X X X Extracts X X X X X X X X Extracts X X X X ..... t filed any application for admission of additional evidences. When all these details are already on the record of the A.O, therefore, there is no necessity on the part of the assessee to file any application for admission of additional evidence. CIT(A), in the instant case has neither perused the details filed before the A.O. nor applied her mind. We, therefore, set aside the Order of the Ld. CIT(A) and direct the A.O. to delete the addition. Grounds raised by the assessee are accordingly allowed. - ITA.No.3668/Del./2017 - - - Dated:- 27-7-2021 - Shri R.K. Panda, Accountant Member And Shri Amit Shukla, Judicial Member For the Assessee : Ms. Piyush Baranwal, C.A. For the Revenue : Shri Mahesh Thakur, Sr. DR ORDER PE ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ordingly disallowed a sum of ₹ 8,04,179/-, being 20% of the total expenditure. In appellate proceedings, the appellant has filed copy of relevant ledger a/c of the expenses along with copy of the major bills. These details were not produced before the Assessing Officer and constitute additional evidence but the appellant has not filed any application under rule 46A for admission of additional evidence. Without prejudice to the aforesaid, the submissions of the appellant have been perused and it is found that there are certain cash payments under this head. Besides, most of the entries are through the ledger accounts of vendors/suppliers and in the absence of copies of their ledger accounts, the modes of payment as well as their o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... page-10 of the paper book. She submitted that the assessee has given the details of break-up of ₹ 40,20,897/- with vendor-wise break-up of amount, TDS deducted thereof and PAN wherever applicable. She submitted that as per the said details, 77% of the expenses related to printing and stationery i.e, OMR sheets as the assessee-company is engaged in conducting exams for various Government bodies. She submitted that two invoices pertain to Rational Business Corporation for ₹ 17 lakhs approximately. She submitted that from November, 2014 till March, 2015 the A.O. never asked any other question to the assessee regarding the said expenses and, therefore, in absence of any query pertaining to the same and other expenses, her satisfact ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e us. We find the A.O. in the instant case has made addition of ₹ 8,04,179/- being 20% of the expenses debited under the head Computer Expenses on the ground that assessee did not produce proper details. We find the Ld. CIT(A) upheld the addition made by the A.O, the reasons of which, have already been reproduced in the preceding paragraph. It is the submission of the Learned Counsel for the Assessee that assessee had filed the requisite details before A.O. and the A.O. without pointing out any defect in the details filed before him has made the disallowance on adhoc basis. Further it is also her submission that the Ld. CIT(A) without verifying the details already filed before the A.O, has simply rejected the claim of the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pertain to the major amount of the computer, printing and stationery expenses of ₹ 31,44,007/-. The Ld. CIT(A) also without going through the details filed before the A.O. has simply rejected the details filed by the assessee before him on the ground that assessee has not filed any application for admission of additional evidences. When all these details are already on the record of the A.O, therefore, there is no necessity on the part of the assessee to file any application for admission of additional evidence. The Ld. CIT(A), in the instant case has neither perused the details filed before the A.O. nor applied her mind. We, therefore, set aside the Order of the Ld. CIT(A) and direct the A.O. to delete the addition. Grounds raised b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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