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TMI Blog2021 (12) TMI 817X X X X Extracts X X X X X X X X Extracts X X X X ..... in law and on facts of the case in upholding the ad-hoc addition of Rs. 12,50,000/- towards personal and non-business use of various expenses (like telephone expenses, staff welfare expenses, vehicle repair and maintenance expenses and depreciation on vehicles etc) despite the fact that all the documents and information was filed before the assessing officer. The addition is made without considering the genuineness of the documents being submitted by the appellant." 2. Briefly stated, the assessee which is engaged in the business of providing of education and consultancy services had filed its return of income for A.Y 2014-15 on 21.11.2014, declaring an income of Rs. 91,28,540/-. The return of income filed by the assessee was processed as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he appellate proceedings had furnished detailed documents to drive home its claim that the A.O. had made an unreasonable addition, the CIT(A), therefore, called for a remand report from the A.O. Vide his report dated 27.10.2017, it was submitted by the A.O that the assessee had in the course of remand proceedings despite 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... im of having incurred the aforesaid expenses wholly and exclusively for the purpose of its business. However, the CIT(A) not finding favor with the claim of the assessee upheld the ad-hoc disallowance of Rs. 12.50 lac made by the A.O. 5. At this stage, we may herein observe, that the 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. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iately preceding year i.e. A.Y 2013-14. Admittedly, it is a matter of fact borne from the record that the A.O had on an ad-hoc basis disallowed an amount of Rs. 12.50 lacs out of the total expenses that were booked by the assessee under the various heads, viz. telephone expenses, miscellaneous expenses, entertainment expenses and depreciation on vehicles aggregating to Rs. 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 th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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