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TMI Blog2022 (2) TMI 222X X X X Extracts X X X X X X X X Extracts X X X X ..... ddition at 1/3 of the development expenses for want of printed receipts and vouchers which were not permissible under law." 3. The brief facts of the case are that the assessee among more than one activity during the year ended 31/03.2013 formed two lay outs by purchasing agricultural lands in Cholavandan near Madura and at Vathalagundu at the foothills of Kodaikanal near Dindigul. Since he agricultural lands were converted into housing sites there were a lot of expenditure on development of the lands into housing sites by dumping a lot of debris in the lands for raising the level of the house sites to road level, by getting all approvals from the various Government Authorities such as Director of Town and Country Planning, Local Panchayat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the development expenditure claimed by the assessee has been far less than the expenditure claimed by the other people for the same and the fact that the Ld. AO ought to have appreciated the fact that the disallowance of a part of the development expenditure in an arbitrary manner at 1/3rd of the expenditure is too huge is not justified. 6. Further, the assessee made his submissions before the Ld. CIT(A) that "it is submitted that the agricultural lands were converted into house sites in villages in far of Madurai and Dindigul relying upon the local big wigs and the claims made by them. The development expenses had been verified by the Auditors while doing the audit work. They had not made any comments in their audit report. The expe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under case laws will not come to the aid of the appellant as the same were on entirely different set of facts. The AO's addition on ad hoc basis require no interference and this proposition is buttressed by several case laws. In the case of Agfa India (P) Ltd., Mumbai vs ACIT (2015), Hon'ble Mumbai Tribunal has held that non-furnishing of documentary evidences during scrutiny proceedings as well as appellate proceedings justifies the additions made by the AO. The relevant are reproduced as under: "That the assessee has not furnished any documentary evidence for the expenses incurred, neither during the assessment proceedings nor during appellate proceedings. Even before the Tribunal, no evidence was furnished to substantiate the c ..... X X X X Extracts X X X X X X X X Extracts X X X X
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