TaxTMI 
TaxTMI 
2024 (8) TMI 342
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....)-Ld. DR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2018-19 arises out of the order of learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A)] dated 08-11-2023 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s. 143 (3) r.w.s 143(3A) & 143 (3B) of the Act on 04-04-20....
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....ector and it was commensurate and reasonable compared to the size of the assessee's business. The same was supported by the fact that until FY 2016-17, the income comprised only of rental income and interest income. However, during FY 2017-18, the commercial project in Panaiyur-ECR road commenced and the assessee started generating revenues for the said project. In this year, the income from this ....
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.... of Sec. 40A (2) (b). The Ld CIT(A) confirmed the disallowance against which the assessee is in further appeal before us. Our findings and Adjudication 3. In our considered opinion, Ld. AO could not sit on the armchair of the businessman so as to judge the reasonableness of the expenditure to the incurred by the assessee for its business purposes unless it is shown that the said expenditure was....
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....t could also be seen that the payee director is sole resident director in India and the other two directors are non-resident and therefore, he would have greater role to play. During this year, the project of the assessee has started generating revenues and the payee director has been involved in day to day affairs of the assessee-company which quite justify the increased payment in this year. The....