Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.
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Step 2 – Draft Generation
Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.
• Relevant statutory provisions • Judicial precedents and Supreme Court, High Court and other citations • Issue-wise legal analysis • Practical arguments and supporting content • Professionally structured draft ready for further review.
Assessee's Appeals Succeed: Ad-hoc Expenditure Disallowance Deleted The appeals by the assessee against the ad-hoc disallowance of expenditure by the Assessing Officer for the Assessment Years 2012-13 and 2013-14 were ...
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
The appeals by the assessee against the ad-hoc disallowance of expenditure by the Assessing Officer for the Assessment Years 2012-13 and 2013-14 were successful. The Judicial Member directed the Assessing Officer to delete the disallowance in both appeals, as it was made on an ad-hoc basis without pointing out any discrepancies in the accounts of the assessee. Consequently, the grounds raised in both appeals were allowed, and the order was pronounced in open court on 16.06.2022.
Issues: - Ad-hoc disallowance of expenditure by the Assessing Officer
Analysis: The judgment involves two appeals by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals) for the Assessment Years 2012-13 and 2013-14. The main issue in both appeals is the ad-hoc disallowance of expenditure made by the Assessing Officer. In the first appeal (ITA No. 277/Asr/2018), the only effective ground raised was that the Ld. CIT(A) erred in sustaining the addition made by the Assessing Officer through ad-hoc disallowance of expenditure amounting to Rs. 2,76,388. The assessee contended that all vouchers supporting the expenses had been furnished and requested the Ld. CIT(A) to verify the same from the assessment record. Despite this, the Ld. CIT(A) sustained the addition of Rs. 50,000 without perusing the record. The Judicial Member found that the Assessing Officer made the disallowance on an ad-hoc basis without pointing out any discrepancies in the accounts of the assessee. Consequently, the Judicial Member directed the Assessing Officer to delete the disallowance, allowing the ground raised in the appeal.
In the second appeal (ITA No. 300/Asr/2018) for the AY 2013-14, the facts were identical to the first appeal. The Ld. DR adopted the same arguments, and since there were no changes in the facts and circumstances, a consistent view was taken. The Judicial Member directed the Assessing Officer to delete the disallowance for this year as well, allowing the grounds raised in this appeal. In conclusion, both appeals filed by the assessee were allowed, and the order was pronounced in the open court on 16.06.2022.
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