2025 (3) TMI 1592

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....(here-in-after referred to as "the Act") relevant to the Assessment Year 2012-13. 2. The assessee in this appeal taken following grounds of appeal :- Grounds of Appeal Tax effect relating to each Ground of appeal 1 On the facts and circumstances of the case and applicable law, Ld. CIT(A) erred in sustaining the assessment order passed by Ld. AO under section 143(3) which is contrary to the material on records and provisions of the Act, unjustand bad in law. NA 2 On the facts and circumstances of the case and applicable law, Ld. CIT(A) erred in sustaining the adhoc disallowance of 25% on account of distribution expenses amounting to Rs. 17,00,701. 5,10,210 3 On the facts and circumstances of the case and appl....

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....establish his institute as reputed institution like that are in Kota (Rajasthan). That for the said purpose, the assessee had to incur advertisement and publicity expenditure to make the institute popular. The ld. counsel has further submitted that all the bills and vouchers were produced before the Assessing Officer, however, the Assessing Officer without pointing out any specific defect or infirmity in the same observed that some of the expenditure was shown by way of self prepared vouchers. He, therefore, disallowed 25% of the advertisement expenses. The ld. counsel has submitted that the disallowances made by the Assessing Officer was not justified. The ld. D.R. on the other hand has relied upon the findings of the Assessing Officer. ....