Disallowance of 20% Miscellaneous Expenses Deemed Arbitrary Due to Lack of Procedure u/ss 145(3) and 144.

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....Disallowance of 20% of misc. expenses - if there is any deficiency in the vouchers or the bills supporting the incurrence of expenditure, then at the most those can be regarded to be non-genuine and can be disallowed - AO has resorted to estimating the disallowance of the claim without resorting to the procedure u/s 145(3) r.w.s 144 - arbitrary and adhoc disallowance not sustainable....