TaxTMI 
TaxTMI 
2021 (8) TMI 236
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....y the revenue: "1. On the facts and in the circumstances of the case, the Ld. CIT(A) has erre in restricting the addition to Rs. 20, 48,705/- as against Rs. 4,13, 42, 756/- made by the AO on account of the "Brand Image" expenses. 2. The Ld. CIT(A) erred in law and on facts in deleting addition of Rs. 1,04,34,368/- made by the A. O. on account of the disallowance of expenses u/ s 14Alncome Tax Act, 1961 read with Rule 8 D. 3. On the facts and in the circumstances of the case, the Ld. CIT(A) has erred in deleting addition of Rs. 2, 32, 976/- made by the A.O. on account of provision towards commission." 3. In ITA No. 9395/Del/2017, following grounds have been raised by the assessee: "1. That having regard to the facts and circumstance....
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....nfirming the action of Ld. AO in not allowing the benefit of additional depreciation of Rs. 1, 70,00,485/- claimed by the assessee under the head 'Plant and Machinery' and that too by recording incorrect facts and findings and in violation of principles of natural justice and in not considering the latest law in his regard. 6. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in not allowing the benefit of deduction of Rs. 21,00,000/- as claimed by the assessee u/ s 35AC and that too by recording incorrect facts and findings and in violation of principles of natural justice and in not considering the latest law in this regard. 7. Without prejudice t....
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.... CIT ( A) examined the bills raised by the assessee of Dewan Travels Pvt. Ltd. which are as under: Sl. No. Date Amount 1. 17.09.2011 Rs. 20,48,705 /- 2. 04.04.2012 Rs. 2,53,17,202/- 3. 26.05.2012 Rs. 1,46,54,700/- 4. 19.07.2012 Rs. 2,34,11,845/- 7. The ld. CIT (A) found that the bill dated 17.09.2011 for an amount of Rs. 20, 48,705/- pertain to the assessment year 2012- 13, hence, disallowed the expenditure to that extent and allowed the remaining expenditure being the amount spent during the year. The disallowance of Rs. 20,48, 705/- has not been contested by the assessee. The ld. CIT ( A) has also verified the list of dealers and their persons who were taken for the foreign junkets in support of the claim of the ....
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....een brought before us, we decline to interfere with order of the ld. CIT ( A). 12. In the result, the appeal of the revenue is dismissed. CO No. 223/Del/2017 : 13. In view of the above adjudication, the CO of the assessee is treated as superfluous and hence dismissed. ITA No. 9395/Del/2017 A.Y. 2014- 15 : Disallowance u/s 14A: 14. The assessee received dividend of Rs. 2,69,77,700 /- which was claimed exempt u/ s 10(34) of the Income Tax Act, 1961. The assessee made disallowance of Rs. 4,03,275/- u/s 14A r.w.r. 8D. The Assessing Officer made disallowance of Rs. 4,93,31,099/- under Rule 8D( ii) and 8D( iii). The ld. CIT ( A) restricted the amount to Rs. 2,65,74,425/- taking into consideration, the amount of Rs. 4,03,275 /- disallowed su....
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....ount of Rs. 8,73,86,301/- claimed in the computation of income on the grounds that the assessee failed to prove the following points: (i) to whom the freebies gifts had been distributed? (ii) what advantage that person had given to the company objectively? (iii) whether without distribution of gifts, foreign junkets the sale of the appellant company would have dipped? (iv) who had travelled, what is the relationship of the person travelled to the appellant company, whether the employee of the company, or the distributors of the company or their family members had travelled? (v) whether the benefit value had been affected to income by that person who had been given the freebies/s, free tour? (vi) whether there is substantial incr....