2010 (9) TMI 25

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.... 22,47,565/- was spent for visits by Sh. Nikhil Nanda, K.Minami and Sh. Vimal Langer to Malasiya and U.K. The Assessing Officer in the assessment year observed that the assessee could not establish that these expenses were incurred for business purposes. He was of the opinion that the aforesaid visits were personal travel of these persons and, therefore, disallowed the expenditure. We reproduce the order of the Assessing Officer to this effect which reads as under:- "During the course of assessment proceedings, it was observed that the assessee had debited the P& L account with Rs. 6.346 crores on account of Traveling and conveyance expenses. The AR was asked to file the details of the foreign traveling which were duly furnished. From th....

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.... development, indigenization of parts, pricing, market understanding etc) which are required to be followed by all group companies of Yamaha Motor Co. Ltd. Japan. The CIT (Appeal), however, was not convinced with the explanation of the assessee for want of any proof in support of the assertion and recorded as under while rejecting the contention of the assessee:- "It is mentioned in the assessment order that during the course of assessment proceedings, the Assessing Officer has observed that the Assessing Officer has observed that the assessee had debited the P&L account with Rs. 6,346 crores on account of Traveling and Conveyance expenses. From the details filed the AO also observed that while the company has a tie up with Japan and has....