2025 (6) TMI 1951

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....ce, Advocates. For the Respondent: Ms. Mamta Omle, Advocate. P. C. 1. The above Appeal takes exception to the order passed by the Income Tax Appellate Tribunal (for short "ITAT") dated 13th September 2017. According to the Appellant the order of the ITAT gives rise to the following Questions of Law:- 1. Whether each assessment year should be treated distinctly/separately for computation of....

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....dences. 2. As far as the proposed Question Nos. 1 and 2 are concerned, they arise from ground No. 2 of the order passed by the ITAT. Ground No. 2 was challenging the order of the CIT (Appeals) which confirmed the ad-hoc disallowance made by the Assessing Officer of Rs. 4,32,541/-, being 5% of various expenses debited to the profit and loss account as not incurred wholly and exclusively for busin....

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....n Nos. 1 and 2 reproduced above are concerned, the same do not arise for our consideration. 3. As far as Question Nos. 4, 5 and 6 are concerned, they are in relation to ground Nos. 3 and 4 of the order of the ITAT. Ground Nos.3 and 4 are in relation to the commission paid by the Assessee to two individuals, namely, (i) Mrs.Nivedita Singh and (ii) Mr. Srikant Saratchandra. According to the Assesse....