TMI Blog2021 (12) TMI 817X X X X Extracts X X X X X X X X Extracts X X X X ..... ify the ad-hoc disallowance on the basis of generalized observations and not on the basis of any concrete material. As observed by the Tribunal in the assessee's own case for the immediately preceding year i.e. A.Y 2013-14, an ad-hoc disallowance without pointing out the specific expenditure the claim for deduction of which by the assessee is not found to be in order, cannot be sustained and is liable to be vacated. Even otherwise the expenses claimed by the assessee during the year under consideration had not witnessed any abnormal rise as in comparison to those of the last two preceding years, which would have otherwise justified drawing of adverse inferences qua the claim for deduction of such expenses during the year under consid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... turn of income for A.Y 2014-15 on 21.11.2014, declaring an income of ₹ 91,28,540/-. The return of income filed by the assessee was processed as such u/s. 143(1) of the Act. Subsequently, the case of the assessee was selected for scrutiny assessment u/s. 143 (2) of the Act. 3. During the course of the assessment proceedings, it was observed by the A.O that the assessee had claimed to have incurred expenditure aggregating to ₹ 3,22,95,400/-, as under : - 1. Miscellaneous expenses : ₹ 13,30,858/- 2. Telephone expenses : ₹ 23823209/- 3. Staff welfare expenses : ₹ 46,90,119/- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ite specific directions not produced before him the complete bills and vouchers for the month of November, 2013. In rebuttal, it was the claim of the assessee, that it was not afforded sufficient opportunity to substantiate its aforesaid claim of expenses and furnish the requisite documentary evidence in support thereof. Accordingly, the CIT(A) vide his letter dated 14.09.2018 again directed the A.O to examine whether the bills and vouchers were properly maintained by the assessee. In the course of the second round of remand proceedings, the A.O called upon the assessee to furnish the complete bills/vouchers of an amount of ₹ 1 lac and above. Also, the assessee was directed to furnish the copies of the remaining bills/vouchers which w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CIT(A) while upholding the aforesaid ad-hoc disallowance of expenses had relied on the order that was passed by his predecessor while disposing off the appeal in the assessee's own case for the immediately preceding year i.e. A.Y 2013-14 in ITA No. 166/2016-17; dated 14.09.2017. 6. The assessee being aggrieved with the order the CIT(A) has carried the matter in appeal before us. At the very outset of the hearing of the appeal, it was submitted by the ld. Authorized Representative( Ld. A.R , for short) for the assessee, that a similar ad-hoc disallowance made by the A.O in the assessee's own case for the immediately preceding year A.Y 2013-14, as was relied upon by the CIT(A) for upholding the ad-hoc disallowance of expenses made ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... expenses, miscellaneous expenses, entertainment expenses and depreciation on vehicles aggregating to ₹ 3,22,95,400/-. As stated by the ld. A.R, and rightly so, there is no mention of any such specific bill/voucher qua the aforesaid expenses in question, as regards which the A.O had carried any doubts; or was of the view that the same pertained to an expenditure that was not incurred wholly and exclusively by the assessee for the purpose of its business. In fact, we find that the A.O had both in the course of the assessment proceedings as well as remand proceedings tried to justify the ad-hoc disallowance on the basis of generalized observations and not on the basis of any concrete material. As observed by the Tribunal in the assessee& ..... X X X X Extracts X X X X X X X X Extracts X X X X
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