2022 (5) TMI 1667

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....13-14. Before us the assessee has assailed the impugned order on the following grounds of appeal: "1. That the order of the Ld. CIT(A) is bad in law as well as on facts. 2. On the facts and in the circumstances of the case, the Ld. CIT(A) has erred in sustaining the following additions/disallowances: A. Rs. 1,50,000/- out of claim of Travelling Expenses of Rs. 14,49,603/- B. Rs. 50,000/- out of claim of communication expenses of Rs. 8,36,570/- C. Rs. 50,000 out of Vehicle Running Expenses of Rs. 3,96,347/- D. Rs. 30,000/- out of claim of depreciation of Vehicles covered by Rs. 7,59,509/- 3. That any other relief/deduction which the Hon'ble Tribunal may deem fit be granted to you....

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....nce of expenses before the CIT(Appeals). However, the CIT(Appeals) not finding favor with the contentions that were advanced by the assessee before him i.e, to the extent it had assailed the disallowances of expenses, sustained the same. 5. The assessee being aggrieved with the order of the CIT(Appeals) has carried the matter in appeal before us. 6. We have heard the Ld. Authorized Representatives of both the parties, perused the orders of the lower authorities and material available on record. On a perusal of the assessment order, we find that the A.O. had on an ad-hoc basis disallowed an amount of Rs. 1,50,000/- out of the assessee's claim for deduction of travelling expenses of Rs. 14,40,603/-. On a perusal of the records, we find ....

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....e cannot be anything personal about such entity. Our aforesaid view is fortified by the judgment of the Hon'ble High Court of Gujarat in the case of Sayaji Iron And Engg. Co. Vs. CIT (2002) 253 ITR 749 (Guj). We, thus, in terms of our aforesaid observations vacate the ad-hoc disallowance of Rs. 1,50,000/- made by the A.O out of travelling & conveyance expenses. 8. As regards the disallowance of Rs. 50,000/- out of the assessee's claim for deduction of vehicle running and maintenance expenses of Rs. 3,96,347/-, we find that the reasons leading to the aforesaid ad-hoc disallowance are no better than those as were there before us as regards its claim for deduction of travelling expenses. On a perusal of the assessment order, we find that th....