2008 (5) TMI 730

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....pellate Tribunal, Delhi Bench 'G' in ITA No. 4307/Del/2004 relevant for the assessment year 2001-02. 2. The assessee is concerned with promoting exports particularly of textiles and readymade garments from India. In the relevant accounting year, the assessee has incurred an expenditure of ₹ 8,19,277 towards entertainment. Out of this, a sum of ₹ 5,88,705 pertained to the enter....

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....ld as follows:- "The Income-tax authorities must put themselves in the shoes of the assessee and see how a prudent businessman would act. The authorities must not look at the matter from their own view point but that of a prudent businessman." (P. 82) 5. Under the circumstances, we are of the view that it was not possible for the Assessing Officer to substitute his opinion of the amount that sh....