2025 (12) TMI 1424

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.... appearing on behalf of the assessee at the outset submitted that the grounds of appeal no. 5 to 10 are in respect of Advertisement Marketing and Sales Promotion Expenditure (AMP). The said issue is now covered by Advance Pricing Arrangement (APA), hence, ground no. 5 to 10 of appeal are withdrawn. He submitted that a letter dated 01.10.2024 to this effect has already been filed. He contended that the only issues that survive for adjudication are ground no. 11 to 13 of the appeal. With regard to Department's appeal he submitted that all the grounds of appeal are relating to Transfer Pricing issues that have been now settled in APA. The ld. DR endorsed the statement made by ld. Counsel for the assessee with respect to the issues raised in....

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....ails of Miscellaneous Expenses. Miscellaneous Expenditure is with respect to meeting and conferences. The Assessing Officer (AO) questioned increase in Miscellaneous Expenditure. The assessee explained that the increase in expenditure was on account of increase in the number of regional meetings with various dealers and distributors with a focus for increase in sales and growth of the company. Further, the expenditure was with regard to Annual General Meetings (AGM). The AO in an arbitrary manner only allowed 50% of expenses though, the expenses were duly supported by the bills. The CIT(A) upheld the same. 3.2. In respect to ground no. 12 he submitted that, the addition is with respect to mis-match in the sales turnover as reported in Au....

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....uding AGM. The AO has merely questioned the increase in expenditure as compared of previous assessment year. The assessee was specifically asked to explain and justify expenditure of Rs. 18,94,950/-. The assessee furnished bills to substantiate expenditure. In addition to the bills assessee also furnished copies of invoices, voucher and proof of payment in respect of the expenditure in relation to the AGM. Once, the assessee has furnished relevant documents to substantiate its claim, no ad-hoc disallowance of the expenditure is warranted. Thus, we find merit in the ground of appeal no. 11, the same is allowed. 8. The ground of appeal no. 12 is with regard to mis-match of sales turnover reported in Audit Report and the ITR. The contention....