2025 (2) TMI 86

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....A.Y. 2013-14. 2. Grounds have been raised by the assessee/ appellant for adjudication in his appeal are as under :- 1. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in and on facts in confirming the action of Ld. AO in making an estimated disallowance of Rs. 3,00,000/- on account of alleged unverifiable purchases. 2. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in and on facts in confirming the action of Ld. AO in making an estimated disallowance of Rs. 1,00,000/- on account of direct expenses. 3. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in ad on facts in confirming the action of Ld. AO in mak....

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....question. The learned AO found that the some bill/ vouchers are missing and some are self generated and so disallowance of Rs. 3,00,000/- was made on account of unverifiable purchases to plug the leakage of revenue. The assessee / appellant was asked to justify the direct expenses which include purchases, wages, other petty expenses related to Tennis Counts maintenance but the learned AO was not found explanation given by the assessee/ appellant satisfactory by observing some discrepancies to like unverifiable signatures shown and payment details were partly produced. Followed by above observance, the learned AO made a disallowance of Rs. 1,00,000/- of direct expenses to plug the leakage of revenue. Aggrieved so, the assessee/ appellant fil....

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....d order, the learned CIT(A) mechanically confirmed the disallowances made in the assessment order without discussing its merit and contentions advanced on behalf of assessee / appellant and impugned order simply based on previous AY 2012-13. 9. In the course, of hearing, the learned AR relied upon the order passed by co-ordinate Bench in the matter Sanjay Minotra Vs. ACIT, Circle - 62(1), New Delhi ITA No.3859/Del/2016 AY 2012-13 in which held that since revenue has not determined the expenses for which bills were missing, lower the disallowance to Rs. 1 lakh from Rs. 7 lakh and Rs. 3 lakhs, of which para 7 reproduced as under :- 7. We find that the Assessing Officer has not brought to fore as to what are the details for which v....