TaxTMI 
TaxTMI 
2025 (7) TMI 1113
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....x Act, 1961 (hereinafter referred to as 'the Act') dated 02.12.2016 by the Assessing Officer, ACIT, Circle-27(1), New Delhi (hereinafter referred to as 'ld. AO'). 2. Ground Nos. 1 and 6 raised by the assessee are general in nature and does not require any specific adjudication. 3. Ground Nos. 2 and 2.1 raised by the assessee are challenging the confirmation of adhoc disallowance made on account of repairs and maintenance expenditure on estimated basis. The inter connected issue involved thereon is the enhancement made by the ld CIT(A) by further disallowance of Rs. 5,06,077/- on account of repairs and maintenance. Ground Nos. 3 and 3.1 raised by the assessee are challenging the ad hoc disallowance of miscellaneous expenses made by the....
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....3}) and added the same to the total income of the assessee. 5. The assessee filed later on the details of total miscellaneous expenses of Rs. 1,59,119/- on which certain discrepancies were found by the ld AO and the ld AO proceeded to disallow 50% of the same amounting to Rs. 79,500/- on estimated basis. 6. Similarly the assessee furnished the bills of total travelling and conveyance expenses of Rs. 12,99,869/- which were found to be more than double the amount of travelling and conveyance as compared to the immediately preceding year. On perusal of the ledger account furnished by the assessee, the ld AO noted that many entries in the ledger account are in the nature of petty cash expenses for which no supporting invoices were shown a....
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....ly on estimated basis by the ld AO which was sought to be upheld by the ld CIT(A). Admittedly the books of account of the assessee company have not been rejected by the lower authorities. The assessee had only furnished sample invoices before the ld CIT(A). The ld CIT(A) simply considered the value of such sample invoices submitted by the assessee and proceeded to hold that the assessee had got no documentary evidences to prove with regard to other expenses incurred by the assessee under the head 'repairs and maintenance' and 'miscellaneous expenses'. We find that assessee had only returned a loss of Rs. 9.43 crores in the return and even after making all the disallowances, assessment was determined at a loss of Rs. 8.52 crores. There could....
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....expenditure of Rs. 6,51,180/- which has been increased to Rs. 12,99,869/- during the year without significant increase in revenue from operations as compared to last year. This is the only reasoning of the ld AO. The personal element of directors travelling could not be simply guessed or assumed by the lower authorities without bringing cogent evidence on record. Further, it is even more pertinent to note that the assessee itself had debited only a sum of Rs. 7,48,290/- on account of traveling and conveyance expenses. It is not known from where the ld AO had taken up the figure of Rs. 12,99,869/-. Even this had not been explained by the lower authorities by facts and figures. However, considering the fact of unverifiable nature of travellin....