Tax Authorities' 20% Expenditure Disallowance Overturned Due to Unjustifiable Allocation Before Project Office Setup in India.

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....Disallowance to the extent of 20% of the expenditure relating it to period prior to the setting of PO in India - when it is not possible to verify if the expenditure were incurred after the establishment of project office or before the establishment of project office, then there is no justification to proportionately appropriate 20% of the expenditure to prior period expenditure. The same being merely whimsical and sustaining it the Ld. FAA has also erred therefore in regard to these grounds the order of ld. Tax Authorities below cannot be sustained and the grounds are allowed. - AT....