2021 (8) TMI 1101

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.... CA Respondent by : Sh. Gaurav Pundir, Sr. DR ORDER PER SUCHITRA KAMBLE, JM This appeal is filed by the assessee against the order dated 12/10/2017 passed by CIT(A)-7, Delhi for assessment year 2013-14. 2. The grounds of appeal are as under:- "1. That the Authorities below erred both in law and on the facts in invoking the provisions of Sec 40A(2)(b) ignoring the facts on r....

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....see company is engaged in the business of publication of education book. The assessee company e-filed its return of income on 30/09/2014 for Ay 2013-14 declaring in income of Rs. 6,50,12,700/-. Order u/s 143(3) was passed on 8/3/2016 thereby assessing an income at Rs. 7,14,31,990/- after making disallowance of Rs. 54 lac u/s 40A (2)(b) of the Act, disallowance of Rs. 46,887/- u/s 14A read with Rul....

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....nd 2014-15, the same was restricted to 15% but in the present assessment year the CIT(A) totally ignored the principle of consistency and has not given any cogent reason for making the said disallowance. Besides this, the CIT(A) has not given any reasons as to how the disallowance has been estimated by the Assessing Officer. Thus, the Ld. AR submitted that the addition should have been deleted. Th....

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....ies Act, 1956 during the previous year 2011-12 & 2012-13. When a Company pays higher salary to the Directors of the Managers or other Officers or employees it is for the commercial expediency of internal affairs of the company, it is not for the Revenue Authorities to decide that particular salary should not have been paid to the Directors. It is the business decision and, therefore, the disallowa....