Ad Hoc 10% Expense Disallowance Invalid as AO Fails to Reject Company Books, Misinterprets Assessee's Entity Type.

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....Ad hoc disallowance of 10% of expenses - Since the AO or the Ld. CIT(A) has not rejected the books of account of the assessee they could not have estimated (ad hoc disallowance of 10%) the expenses claimed to have been incurred by the assessee. Moreover, the AO has made the ad hoc disallowance on the supposition that there might be personal expenditure - AO did not notice that the assessee is a company and not a Firm or proprietary concern etc. So, his reason for disallowance also fails - AT....