2024 (8) TMI 342

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....spondent by : Shri R. Mukundan (JCIT)-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 14....

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....e expertise and experience of the said director 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 pr....

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.... Lacs was disallowed invoking the provisions 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 u....

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....s substantial increase in revenue in this year. It 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 quit....