2021 (10) TMI 827

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....ell as adhoc disallowance of labour / assortment charges as made by Ld. AO in the assessment order. Ground No.1 has not been pressed before us and therefore, the same stand dismissed as being not pressed. In ground no.2, the assessee has contested the confirmation of 10% adhoc disallowance of labour / assortment charges. 2. The assessee, vide letter dated 15/09/2021, has filed an additional ground challenging the disallowance made u/s 14A. Since the same arises out of the assessment order, it is admitted in term of the decision of Hon'ble Apex Court in National Thermal Power Corporation Ltd. V/s CIT (1998; 229 ITR 383). The assessee seeks deletion of disallowance u/s 14A in terms of the decision of Hon'ble Apex Court in Pr. CIT V/s Oil Ind....

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....of appeal. Adhoc disallowance of Labor / Assortment Charges 5.1 The assessee claimed assortment / labour charges for Rs. 777.80 Lacs. Upon perusal of sample supporting bills, vouchers etc., it was noted by Ld. AO that the nature and particulars could not be verified, few documents were not affixed with revenue stamps and in some cases, the payees could not be verified. Accordingly, Ld. AO estimated an adhoc disallowance of 10% against the same. The Ld. CIT(A) confirmed the same since the assessee did not appear during appellate proceedings. 5.2 The Ld. AR assailed the disallowance by submitting that the Books of Accounts have not been rejected and the adhoc disallowance thus made would not be sustainable in law as per the decision of Ho....