Partial disallowance of land development claimed as stock-in-trade expense restricted after mixed evidence on substantiation.

Land filing and development expenses claimed for land held as stock-in-trade were accepted only partly because the supporting bills, books and supplier records substantiated the business transactions, but the evidence was not sufficient to support the claim in full. The full disallowance was therefore not sustained; it was restricted to 10% of the aggregate expenditure, granting partial relief on the claim.

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Issues: Whether the disallowance of land filing and development expenses incurred for land held as stock-in-trade and sold during the year was justified in full, or whether only a part of the claim deserved disallowance.

Analysis: The expenditure was claimed in relation to the assessee's business of purchase and sale of land and immovable properties. The supporting bills and books reflected the transactions, and the corresponding supplier had also recorded them in its accounts. At the same time, the evidence was not found wholly sufficient to establish the claim to the fullest extent, so the expenditure was not accepted in entirety.

Conclusion: The full disallowance was not sustained and was restricted to 10% of the aggregate expenditure, resulting in partial relief to the assessee.

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