2023 (9) TMI 160

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....espondent : None present. P.C. : 1. The following substantial questions of law are proposed : a. Whether on the facts and in the circumstances of the case an in Law, the Hon'ble ITAI was correct in holding that expenses in respect of Sales Support Services and Management Fee had no direct nexus with the project and was not subject to proportionate disallowance as per Accounting Stan....

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....on of a residential project "The Address" at Bandra (East), Mumbai. Respondent had debited a sum of Rs. 2,75,87,391/- and Rs. 26,40,390/- on account of Sales Support Services and Management Expenses, respectively. The Assessing Officer ("AO") allowed 26.32% of these debited amounts because in the opinion of AO, Respondent followed Project Completion Method of accounting and the project was complet....

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....tire additions/disallowances but upheld the disallowance of 25% of the travelling expenses debited by Respondent in its Profit and Loss Account. 4. The dissatisfied Revenue preferred an Appeal before the Income Tax Appellate Tribunal ("ITAT"). ITAT dismissed the Appeal and upheld the view expressed by the CIT(A). It is this order of ITAT which is impugned in this Appeal. 5. Respondent though....

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....diture had also been incurred in subsequent Assessment Years, viz., 2011-2012 and 2012-2013. The CIT(A) came to the conclusion that it was not a one-time expenditure incurred in Assessment Year 2010-2011, which is the year in question or that the expenditure incurred would provide Respondent any benefit of enduring nature. 7. On facts, a conclusion has been arrived at that it was incurred towar....