2022 (8) TMI 1211

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....e, the Ld. CIT(A) has erred in law and facts in deleting the addition of Rs. 1,52,11,000/- made by the A.O. (Rs.1,41,11,000/-on account of disallowing the challan paid in the name of Sh. Harish Kumar & Rs.11,00,000/- on account of disallowing the subvend fee paid.) during assessment proceedings. The Ld. CIT(A) merely considered the statement of Sh. Harish Kumar without verification of any documentary evidence and deleted the said addition without appreciating the facts of the case mentioned in detail in assessment order. 2. That there is violation of law evident from the facts of the case and the same cannot be regularized by any other law enforcing agency under the provision of any other statute. In this case assessee claimed expe....

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....in the name of Sh. Harish Kumar, Rs. 11,00,000/- on account of disallowance the sub vend fee paid. The Ld. DR further submitted that, there is a violation of law evident from the facts of the case and same cannot be regularized by L-1 under the provision of any other statute. The assessee has claimed expenses of L-1 which was allotted to some other person by the Excise and Taxation Department, and the same is not rightly eligible expense of the assessee as he was not eligible for allotment of L-1 license. Further contended that, the entire approach of the Ld.CIT(A) is erroneous. The Ld.CIT (A) has committed a grave error in allowing the Appeal of the assessee. 7. Per contra, the Ld. Counsel for the assessee submitted that, the CIT(A) has....