Messing expenses disallowance deleted where estimates lacked support and no evidence showed partners' personal expenditure.

Disallowance of messing expenses was deleted because the estimates used by the lower authorities were not supported by the record. The Tribunal found that the expenditure was incurred for staff meals and up-country clients, and there was no material to show that any part of it represented partners' personal expenses. Acceptance of a similar disallowance in an earlier year did not justify sustaining the addition, because each assessment year must be decided on its own facts.

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Issues: Whether the disallowance sustained out of messing expenses was justified on the ground that the expenditure lacked full voucher support and allegedly included partners' expenses.

Analysis: The assessee had incurred expenditure on meals for staff and up-country clients, and the Tribunal found the estimates adopted by the lower authorities to be unsupported by the record. It was held that there was no material to show that any portion of the messing expenses represented partners' expenses. The fact that a similar disallowance had been accepted in an earlier year did not justify sustaining the present disallowance, since each assessment year stands on its own facts.

Conclusion: The disallowance sustained by the first appellate authority was not justified and was deleted, with the result that the assessee succeeded on the issue.

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