2025 (6) TMI 700

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....DER PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2015-16 is directed against DCIT, Circle-2(1)(2), Intl. Taxation/Assessing Officer, New Delhi's order dated 30.12.2018 involving proceedings under section 144C(13)/143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). 2. The assessee pleads the following substantive grounds in the instant appeal: ....

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....s of section 40(a)(ia) of the Act, 4. That on facts and in law the AO/DRP have erred in making / upholding disallowance @ 30% of following expenses by invoking provisions of section 40(a)(ia) of the Act: (a) Professional Fees of Rs 1,06,000/- (b) Drafting Expenses of Rs 2,69,200/- (c) Consultancy Charges of Rs 1,35,000/- That the appellant prays for the leave to add, alter, amend an....

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....n the given facts is that the impugned expenditure had been incurred in the earlier assessment years, it is not allowable in the impugned assessment year going by section 37(1) of the Act. It could hardly dispute the assessee's clinching claim of crystallization thereof in the relevant previous year only. 5. That being the case, we hereby quote (2022) 141 taxmann.com 108 (Del), ACIT Vs. National ....