Carting expenses disallowance failed where separate invoices and vouchers showed transportation charges were billed independently of purchases.

Carting expenses were held allowable where the assessee showed, through separate invoices, debit notes and vouchers, that transportation charges were separately billed by cement suppliers and were not included in purchase value. The disallowance on the footing of double debit failed because the assessee's detailed reply and supporting records were not addressed in the assessment or appellate order. On the material produced, the foundation for treating the expenditure as duplicated could not be sustained, and the disallowance was deleted in favour of the assessee.

---

---

Issues: Whether the disallowance of carting expenses on the footing of double debit was justified when the assessee produced separate invoices, debit notes, and vouchers showing that transportation charges were separately billed and paid to cement suppliers.

Analysis: The assessee consistently maintained that the carting charges were separately invoiced by the cement suppliers through debit notes and were not included in the purchase value recorded under purchases. Sample invoices, debit notes, and accounting vouchers were placed on record to support this stand. The detailed reply dated 10.04.2021 and the supporting material were not dealt with in the assessment order or the appellate order. Where relevant submissions and evidence are ignored, the foundation of the disallowance cannot be sustained.

Conclusion: The disallowance of carting expenses was not justified and was deleted in favour of the assessee.

---