2025 (6) TMI 700

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....t : Sh. Vijay B. Basanta, CIT(DR) ORDER 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 ....

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....enditure incurred of Rs 1,77,64,750/- is to be disallowed as per provisions 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) Cons....

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....he relevant formalities followed by crystallization thereof. 4. The Revenue's case, on the other hand, in 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 previo....