2025 (7) TMI 517

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....its return of income for the A.Y 2017-18 on 29/10/2017 admitting total loss of Rs. 22,97,14,286/- under the normal provisions of the I.T. Act, 1961 and the said return was revised on 30/10/2018 and admitted total loss of Rs. 11,75,58,268/-. The assessment has been completed u/s 143(3) of the Act on 30/12/2019 where the Assessing Officer has made adhoc disallowance @30% of site maintenance expenditure of Rs. 1,49,42,675/- and made addition of Rs. 44,82,802/- on the ground that, the expenditure incurred under the head "site maintenance expenses" are supported only by internal self-made voucher and hence, not amenable for verification. 3. On appeal, the learned CIT (A) sustained the additions made by the Assessing Officer. 4. Aggrieved by th....

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....ucher. The muster roll maintained by the assessee is not supported by attendance register and it is not verifiable. Therefore, the Assessing Officer, after considering the relevant fact has rightly made 30% adhoc disallowance of expenditure and the same has been upheld by the learned CIT (A). Therefore, he submitted that the order of the learned CIT (A) should be upheld. 7. We have heard both the parties, perused the material available on record and gone through the orders of the authorities below. Admittedly, the appellant is a company and maintaining regular books of account for its business. It is also not in dispute that, the books of account maintained by the appellant are audited by an Accountant. The Assessing Officer did not reject....