TMI Blog2023 (2) TMI 686X X X X Extracts X X X X X X X X Extracts X X X X ..... xpenses to have been incurred wholly and exclusively for the purpose of business by way of filing cogent supportive evidence. We thus affirm the instant latter disallowance of sales promotion expenses as well. - Decided against assessee. - ITA.No.101/PUN./2022 - - - Dated:- 5-1-2023 - SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND DR. DIPAK P. RIPOTE, ACCOUNTANT MEMBER For Assessee : -None- For Revenue : Shri M.G. Jasnani ORDER PER SATBEER SINGH GODARA, J.M. This assessee s appeal for assessment year 2010- 2011, arises against the CIT(A), Pune-12, Pune's order dated 28.12.2021, in Din Order No.ITBA/APL/S/250/ 2021- 22/1038187658(1), involving proceedings under section 143(3) of the Income Tax Act, 196 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earned on the investment of Rs.17244849, which is the opening balance as well as the closing balance. Considering the same, the disallowance under Rule 8(2)(iii) is determined at one-half percent of the same i.e. Rs.86224/-. Therefore, the disallowance is to be confirmed to the extent of Rs.86224/- only and the remaining addition made by the AO should be deleted. However, while giving effect to this order, the AO is directed to verify the amount of investment and the consequent disallowance. This ground of appeal is partly allowed. 4. Suffice to say, it has come on record that the CIT(A)'s has already taken note of the settled legal proposition on the instant issue. We thus find no merit in the assessee s instant sole substantive ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be allowed. 3.2. I have considered the submission of the appellant as well as facts of the case. It is seen that the AO has disallowed these expenses as the appellant neither filed any bills in support of the same nor the appellant could establish that these were incurred for the business of the appellant. Before me, the appellant filed copies of bills and contended that the appellant has acquired an Aurangabad based manufacturing unit and after starting manufacturing activities, the appellant organized a meeting with its customers, suppliers and bankers at Hotel J W Marriot and these expenses in respect of such meeting are wholly and exclusively for business. However, the appellant neither filed any details of the unit acquired nor ..... X X X X Extracts X X X X X X X X Extracts X X X X
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