Business expense verification supported deletion of unsupported additions, while proportionate disallowance remained for inadequately substantiated expense heads.

Verification of vouchers and bills during remand proceedings supported deletion of additions for allegedly unverifiable business expenses where no specific defects were identified. A proportionate disallowance remained for expense heads lacking adequate supporting material, control, or explanation. The notes state that the Tribunal accepted these concurrent fact-based findings and that no substantial question of law arose regarding deletion of the remaining additions.

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Issues: Whether deletion of additions for allegedly unverifiable business expenses, after sustaining a proportionate disallowance, gave rise to a substantial question of law.

Analysis: The appellate findings established that vouchers and bills produced during remand proceedings had been verified and no specific defect was identified. A proportionate disallowance was nevertheless sustained for expense heads lacking adequate supporting material, control, or explanation. The Tribunal affirmed this fact-based determination, including the sustained disallowances, and the findings were concurrent.

Conclusion: No substantial question of law arose; the deletion of the balance additions was sustained in favour of the assessee.

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