2019 (9) TMI 1514

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....t invoking provisions of Section 145(3) of the Income Tax Act, 1961. Appellant prays that ad hoc addition so made is not in accordance with law and deserves to be deleted. 1.1. That, ld. CIT(A) erred in confirming the action of ld. A.O. in making ad hoc addition without pointing out any single instant where the expenses claimed were in excessive or nor for the purposes of business. 2. That the appellant craves the right to add, delete, amend or abandon any of the grounds of appeal either before or at the time of hearing of appeal." 2. The assessee is a partnership firm and engaged in the business of wholesales cum retails in the trade of fertilizers. The assessee filed its return of income U/s 139(1) of the Income Tax A....

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....rom .15% to .31% during the year under consideration, therefore, merely because G.P. is reduced due to increase in the turnover. Once the N.P. is higher than the preceeding year, the ad hoc disallowance is called for. 4. On the other hand, the ld DR has relied upon the orders of the authorities below and submitted that when the assessee has failed to produce supporting evidence of expenditure then the disallowance made by the A.O. of Rs. 1.50 lacs is reasonable and proper. 5. I have considered the rival submissions as well as relevant material on record. The A.O. has given reasons for making ad hoc disallowance of Rs. 1.50 lacs that too as a lump sum trading addition as the freight expenses were not fully supported by proper bills and....