2025 (2) TMI 608

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....PAC [CIT(A)], Delhi (for short CIT(A)" upholding the disallowances in respect of travelling expenses of Rs. 3,56,661/- and reimbursement of expenses u/s.40(a)(ia) of Rs. 64,41,834/- made by A.O. is wholly illegal, unlawful and against the principles of natural justice. 2.1 The Id. CIT(A) has grievously erred in law and or on facts in upholding the disallowances in respect of travelling expenses of Rs. 3,56,661/- and reimbursement of expenses u/s.40(a)(ia) of Rs. 64,41,834/- made by A.O. 2.2 That the in the facts and circumstances of the Id. CIT(A) ought not to have upheld the disallowances in respect of travelling expenses of Rs. 3,56,661/- and reimbursement of expenses u/s.40(a)(ia) of Rs. 64,41,834/- made by A.O. It is, therefore, p....

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....41,834/- in respect of reimbursement of expenses under Section 40(a)(ia) of the Act 4. Being aggrieved by the Assessment Order, the assessee filed appeal before the CIT(A). The CIT(A) partly allowed the appeal of the assessee. 5. The Ld. AR submitted that the CIT(A) was not right in disallowing the Travelling Expenses of Rs. 3,56,661/- and reimbursement of expenses under Section 40(a)(ia) of the Act of Rs. 64,41,834/-. The Ld. AR submitted that the CIT(A) in respect of disallowance relating to Travelling Expenses restricted the disallowance to 25% but the same should have been allowed as the expense was solely for the purpose of business exigencies and the assessee has demonstrated various details that the assessee's business has increase....