TMI Blog2021 (8) TMI 1145X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee had to shift its business premises because it was required to surrender under lock and key to the bank. No doubt, the assessee put in its appearance twice before the AO but did not furnish books of account which could have enabled the AO to examine and verify the details. AO in such circumstances should have found out a reasonable amount of deductible expenses on a certain parameter rather than disallowing the entire expense. Neither the AO was justified in making total disallowance of expenses nor the CIT(A) was justified in coming to the conclusion that no interest disallowance could be made without proper verification and further deleting disallowance by 90% of the remaining expenses. On a pertinent query, the ld. AR sub ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cts of the quantum appeals are that the assessee filed its return declaring loss of ₹ 2,48,40,695/-. The case was picked up for scrutiny. Several notices were sent to the assessee but the assessee did not respond. A final show cause notice was issued requiring the assessee to appear in person and furnish details of various expenses claimed in the Profit and loss account amounting to ₹ 10,38,10,831/-. The assessee appeared and filed written submissions but did not furnish any bills/vouchers relating to the expenses. Another opportunity was granted. The assessee appeared in the next opportunity also but could not produce the bills and vouchers. The Assessing Officer (AO) added back total of expenses amounting to ₹ 10.38 cror ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , it was the assessee who was at fault. The ld. AR submitted that the assessee had to shift its business premises because it was required to surrender under lock and key to the bank. No doubt, the assessee put in its appearance twice before the AO but did not furnish books of account which could have enabled the AO to examine and verify the details. At the same time, the AO in such circumstances should have found out a reasonable amount of deductible expenses on a certain parameter rather than disallowing the entire expense. In such a situation, neither the AO was justified in making total disallowance of expenses nor the ld. CIT(A) was justified in coming to the conclusion that no interest disallowance could be made without proper verifica ..... X X X X Extracts X X X X X X X X Extracts X X X X
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