Business expense disallowance reduced after lack of proof, as 50% estimate was held excessive and cut to 10%.

Routine business expense claims in a custom house clearing business must be substantiated with supporting evidence; where the full claim is not proved, a reasonable estimation of disallowance may be made. The 50% disallowance was found excessive and unsupported by relevant market comparables, so it was restricted to 10%, granting partial relief to the assessee.

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Issues: Whether the disallowance of routine business expenses claimed in the assessee's custom house clearing business was justified, and if so, to what extent.

Analysis: The assessee failed to substantiate the full claim of expenditure with necessary supporting evidence. At the same time, the disallowance of 50% was found to be excessive and not supported by relevant market comparables. A balanced estimation was therefore warranted by restricting the disallowance to 10%.

Conclusion: The disallowance was reduced from 50% to 10%, granting partial relief to the assessee.

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