1976 (11) TMI 89

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....f Rs. 1,165 of which half were disallowed by the ITO as not being for business purposes. This disallowance was reduced on appeal by the AAC to 1/3rd. It is now contended that this disallowance is too high and should be reduced to 1/4th. It is pleaded that the nature of business carried on by the assessee was such that the car was being mostly used for business purposes and seldom for private purposes. From the chart of expenses claimed and allowed in the past, we found that in the asst. yr. 1970-71, the entire claim of Rs. 1,053 was allowed, although in the earlier years the disallowance was being made at one half of the claim. Perhaps in the asst. yr. 1970-71 the Department realised that the car expenses were incurred wholly for the purpos....

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....allowed in the head office and out of Rs. 6,822, a sum of Rs. 1,000 was disallowed inBhopaloffice i.e. the branch. We find from the chart filed before us that in the previous years also some disallowance were made under this head. It cannot therefore, be said that the entire expenditure incurred under this head could be said to have been incurred wholly and exclusively for the purposes of business and no personal expenses on behalf of the partners were included. However, having regard to the nature of business, we think the disallowance is slightly on the high side. We would reduce the disallowance in the head office to Rs. 500 and in the branch to Rs. 750. We may, also ad that in the branch there was an increase under this head from Rs. 3,....