TaxTMI 
TaxTMI 
2013 (6) TMI 842
X X X X Extracts X X X X
X X X X Extracts X X X X
....sh Saini, J.M.: Both the appeals by the Revenue are directed against different orders of the ld. CIT(A), Gwalior dated 12.10.2012 for the assessment year 2003-04. 2. In ITA No. 05/Agra/2013, the Revenue challenged the deletion of addition of ₹ 18,17,550/- made on account of disallowance of amount debited in grant and aid account. The ld. CIT(A) noted that the AO while competing the assess....
X X X X Extracts X X X X
X X X X Extracts X X X X
....r appeal before the ld. CIT(A). The assessee for claim of deduction of salary submitted before the ld. CIT(A) that the assessee is running a school in which over 3000 students are studying. To impart proper education to these students, sufficient number of teachers have been retained and salary have been paid to the teachers and salary of some of the teachers was being partly reimbursed by the Gov....
X X X X Extracts X X X X
X X X X Extracts X X X X
....d held that the expenditure claimed on account of advance salary paid to the sanctioned staff is revenue in nature and accordingly deleted the addition of ₹ 18,17,520/-. 3. The ld. DR relied upon the order of the AO and submitted that when the amount is to be reimbursed by the Government of M.P. and no claim is made for deduction of the expenditure, therefore, such addition should not have ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....iness should have been allowed as deduction in favour of the assessee if expenditures are incurred wholly and exclusively for the purpose of business or profession. The assessee claimed that the amount of the salary was to be reimbursed by the M.P. Government. Therefore, it was treated as advance salary to sanctioned staff, but vide letter dated 25.10.2001 when the government intimated that there ....