2025 (11) TMI 1825

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.... grounds of appeal: "1. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the addition of Rs. 40,34,000/- made on account of disallowance u/s 40(a)(ia) of the Act, without appreciating the fact that the assessee did not furnish details of expense for verification? 2. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the addition of Rs. 2,16,90,868/- made on account of disallowance of Network set up expenses, without appreciating the fact that the assessee did not furnish details of expense for verification? 3. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) ....

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..... 4. Aggrieved by the order passed by Ld. CIT(A), the Department is now in appeal before us. On hearing both the parties before us and on perusal of assessment records, we note that in the assessment order, the Assessing Officer made disallowances aggregating to Rs. 8,12,33,410/- under three heads, namely: (i) disallowance under section 40(a)(ia) amounting to Rs. 40,34,000/-, (ii) disallowance of network maintenance expenses of Rs. 2,16,90,868/-, and (iii) disallowance of unsubstantiated expenses of Rs. 5,55,08,542/-. We note that additional evidences were placed on record before CIT(Appeals), who also sought a remand report from the concerned Assessing Officer. We observe that the Assessing Officer, in the remand proceedings, after issu....