2018 (4) TMI 175

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....ssment year 2010-11 on the grounds inter alia that :-  "On the fact and in the circumstances of the case the Ld. CIT (A) has erred in:- 1. The order of Ld. CIT (A) is not correct in law and facts. 2. On the facts and circumstances of the case the Ld. CIT (A) has erred in deleting the addition of Rs. 1,62,629/- made by the AO on account of disallowance of Business Promotion Expenses. 3. On the facts and circumstances of the case the Ld. CIT (A) has erred in law in restricting the addition to Rs. 5,57,712/- out of total addition of Rs. 11,51,424/- made by AO on account of Disallowance of Foreign Travelling Expenses. 4. On the facts and circumstances of the case the Ld. CIT(A) has erred in deleting the addition of Rs. 61,00....

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....in deleted the addition of Rs. 61,00,000/- by partly accepting the appeal of the assessee. Feeling aggrieved, the Revenue has come up before the Tribunal by challenging the impugned order passed by ld. CIT (A). 4. We have heard the ld. Authorized Representatives of the parties to the appeal, gone through the documents relied upon and orders passed by the revenue authorities below in the light of the facts and circumstances of the case. GROUND NO.1 5. Ground No.1 is general in nature, hence does not require any adjudication. GROUND NO.2 6. Bare perusal of page 2 para 2 of the assessment order goes to show that the AO has made disallowance without disputing the business promotion expenses, claimed by the assessee company, on es....

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....sidered view that ld. CIT (A) has merely restricted the addition to 50% instead of 25% made by the AO following his own order passed in AY 2008-09 in assessee's own case which is stated to have not been challenged further. So, again, we find no illegality or perversity in the findings returned by the ld. CIT (A). Ground No.3 is determined against the Revenue. GROUND NO.4 8. Undisputedly, during the search and seizure operation conducted u/s 132 of the Income-tax Act, 1961 (for short 'the Act') at the premises of M/s. Shiv-Vani Group and its associates and its Directors, certain documents were seized and one such document was qua property bearing space no.4 measuring 4,395 sq.ft. on the 7th floor of the building Royal Retreat-II, Charm....