Deduction claims require credible evidence; unsupported travelling allowance and commission expenses were disallowed for lack of proof.

Deductibility of travelling allowance and kuri canvassing commission depended on adequate substantiation. The assessee failed to produce valid supporting documents for the full travelling allowance claim, so only part of the expenditure was accepted and the balance disallowed. For the canvassing commission, the Tribunal found the claim unproven because the recipient could not identify any subscriber allegedly canvassed, leaving the payment inadequately established. The article states that a deduction claim must be supported by credible evidence, and a disallowance based on insufficient proof and adverse factual findings will not be disturbed in appeal.

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Issues: (i) Whether the disallowance of part of the travelling allowance claimed by the assessee was justified for want of supporting evidence; (ii) Whether the disallowance of a portion of the kuri canvassing commission was rightly sustained.

Issue (i): Whether the disallowance of part of the travelling allowance claimed by the assessee was justified for want of supporting evidence.

Analysis: The assessee did not produce valid documents to substantiate the full claim for travelling expenses. The appellate authorities and the Tribunal assessed the material on record and accepted only a portion of the claim, declining full allowance in the absence of satisfactory proof.

Conclusion: The disallowance of part of the travelling allowance was upheld, and the claim for the entire amount was rejected.

Issue (ii): Whether the disallowance of a portion of the kuri canvassing commission was rightly sustained.

Analysis: The commission related to payments said to have been made to the son of a director. The Tribunal found that he could not identify any subscriber whom he had allegedly canvassed, and the claim was therefore not satisfactorily established.

Conclusion: The disallowance of the kuri canvassing commission was rightly sustained.

Final Conclusion: The appeal failed on both issues, and the Revenue's position was sustained in full.

Ratio Decidendi: A claim for deduction of expenditure must be supported by credible evidence, and a disallowance based on inadequate substantiation and adverse factual findings will not be interfered with in appeal.

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