2025 (5) TMI 32

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Lovish Shelly, Sr. DR ORDER PER SONJOY SARMA, JUDICIAL MEMBER: The present appeal has been preferred by the assessee against an order dated 16.12.2024 of the Commissioner of Income Tax (Appeal) ADDL/JCIT-12, Mumbai [hereinafter referred to as 'CIT(A)'] passed u/s 250 of the Income Tax Act (hereinafter referred to as the 'Act'). 2. Brief facts of the case are that the assessee filed its....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....xpenditure was to be allowed and thereby, the assessee made a fresh claim and pleaded before the Assessing Officer to allow the expenditure to the extent of Rs. 11,80,000/- by reducing the total income to that extent. However, the Assessing Officer ignored this submission of the assessee and no fact has been mentioned in the assessment order and the assessment was completed without considering the....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....aid club entrance fees was incurred purely for the purpose of improving its business and he therefore, relied on the various judicial pronouncement including the decision of Hon'ble Apex Court in the case of CIT vs. United Glass Mfg. Co. Ltd. reported in (2012) 28 taxmann.com 429 (SC). The ld. AR also argued that the duty of the Assessing Officer is not only to assess but also to determine the cor....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....12.2019, however, the Assessing Officer neither considered nor discussed the same which is against the principles of natural justice. Similarly, the ld. CIT(A) also did not record any findings on the issue but simply dismissed the appeal of the assessee. We also note that the said club entrance fees were incurred for the promotion of the business interest and hence the same is an allowable expendi....