TaxTMI 
TaxTMI 
2024 (12) TMI 1008
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.... 2. In this appeal, the assessee has raised the following grounds: - "The following grounds of appeal are without prejudice to one another:- 1. On the facts in circumstances of the appellant's case and in law the order passed by the Ld. CIT(A) u/s. 250 of the Income Tax Act, 1961 (the Act) dated 27-05-2024 the same is erroneous and prejudicial to the interest of natural justice and fair play. 2. On the facts in circumstances of the appellant's case and in law the Ld. CIT(A) erred in holding that the consultancy fees of Rs. 23,08,963/- should be disallowed without considering the fact that we have provided proof of all the expenses and hence the question of disallowing consultancy charges does not arise. 3. On the facts in c....
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.... of Rs. 30,84,100/- out of the total expenses amounting to Rs. 53,93,063/- claimed by the assessee and the balance expenditure of Rs. 23,08,963/- was disallowed under section 37 of the Act. Further, the AO observed that the assessee has claimed expenditure on account of power and fuel expenses amounting to Rs. 41,93,050/-. However, bills of only Rs. 1,99,092/- were furnished by the assessee. Accordingly, the balance expenditure of Rs. 39,93,958/- was disallowed under section 37 of the Act. 4. The learned CIT(A), vide impugned order, inter alia, upheld the additions made on account of consultancy and legal charges as well as power and fuel expenses. In respect of consultancy and legal charges, the learned CIT(A) held that none of the person....
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....provided the details of 87% of the expenditure incurred on consultancy and legal fees and only in respect of expenditure amounting to Rs. 23,08,963/-, the assessee could not furnish any details during the assessment proceedings. It is evident from the record that with respect to payment amounting to Rs. 23,08,963/-, the learned CIT(A) upheld the addition on the basis that none of the persons to whom consultancy charges were paid has filed their return of income. In order to substantiate its claim of payment for consultancy fees, the assessee has placed on record the documents pertaining to the individuals to whom such payment was made along with declaration and KYC. From the perusal of these documents, forming part of the paper book from pa....
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.... present appeal before us, the assessee has furnished the documents pertaining to power and fuel expenses and also provided a copy of the bills. As per the assessee, the premises where it has provided the manpower services and incurred the expenditure in the nature of power and fuel were on rent and therefore, these bills/vouchers are in the name of the property owners instead of the assessee. In order to support the aforesaid submission, the assessee has submitted the copy of the rent agreements with regard to these premises, forming part of the paper book from pages 283 to 402. As per the assessee, out of the disallowance of Rs. 39,93,958/-, it has been able to co-relate the documentation for the expenditure to the tune of Rs. 10,42,713/-....