Business expenditure reimbursement claims require supporting evidence, and unsupported partner reimbursements may be sent back for fresh verification.

Partner reimbursements for car maintenance, office maintenance and client entertainment require verifiable bills and invoices to establish that the expenditure was actually incurred and was wholly and exclusively for the firm's business. Where such supporting evidence was not produced before the Assessing Officer, the claim could not be conclusively accepted or rejected on the existing record. The consistency principle was held inapplicable because the issue had not been examined in earlier years. The matter was therefore remitted for fresh verification and reconsideration in accordance with law.

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Issues: Whether the disallowance of partner reimbursements towards car maintenance, office maintenance and client entertainment was sustainable in the absence of supporting bills and invoices, or whether the matter required fresh verification.

Analysis: The reimbursements were claimed to have been incurred by the partner and charged to the firm under the partnership deed, but the supporting bills and invoices were not produced before the Assessing Officer. The ledger accounts showed that amounts had been debited by the partner and reimbursed by the firm, yet the existence of actual expenditure and its nexus with the business of the firm had not been verified at the assessment stage. As the issue had not been examined in earlier years, the consistency principle was held inapplicable. In the interest of justice, the matter was restored to the Assessing Officer for fresh adjudication after verification of the relevant bills.

Conclusion: The disallowance was not finally affirmed or deleted, and the issue was remitted to the Assessing Officer for reconsideration in accordance with law.

Ratio Decidendi: A claim for reimbursement of business expenditure must be supported by verifiable evidence establishing that the expenditure was incurred wholly and exclusively for business purposes; where such verification is absent, fresh examination by the Assessing Officer is warranted.

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