2021 (7) TMI 436

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....r. Sushil Kumar Mishra, DR ORDER PER S. RIFAUR RAHMAN, A.M. This is an appeal filed by the assessee. The relevant assessment year is 2014-15. The appeal is directed against the order of the Commissioner of Income Tax (Appeals)-4, Mumbai [in short 'CIT(A)'] and arises out of the assessment completed u/s 143(3) of the Income Tax Act 1961, (the 'Act'). The appeal was filed by the assessee....

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....ssessee are, during the assessment proceedings, the Assessing Officer observed from the previous assessment order and profit and loss account that the assessee has debited staff welfare expenses to the extent of Rs. 32,90,908/- conveyance expenses at Rs. 40,58,630/-, general expenses at Rs. 11,25,644/- and office maintenance expenses at Rs. 24,86,099/-. The total of the above expenditures works ou....

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....ferred an appeal before CIT(A)-4, Mumbai, at the time of appellate proceedings, the assessee was asked to produce all bills and vouchers for verification. However, the assessee could not submit the same before first appellate authority even though several opportunities were given to assessee. Since no detail were submitted in appellate proceedings, Ld. CIT(A) sustained the addition made by the AO.....

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.... heads to the extent of 10% of the total claim of the assessee. The only reasons attributed by the authorities are that these expenses were incurred in cash and booked on the basis of self-made vouchers. In our opinion, the disallowance was purely made on the basis of presumptions and surmises and ad-hoc in nature without pinpointing any specific defects or deficiencies. Therefore, we deem it fit ....