TaxTMI 
TaxTMI 
2025 (3) TMI 1708
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....06.2024. 1.1 In this case, the Ld. AO made three additions as under: (a) Rs. 7,27,249/- by disallowing certain expenses claimed as business expenses. (b) Disallowance u/s 40(a)(ia) of Rs. 44,630/-. (c) Rs. 87,500/- disallowed on account of rent expenses. 1.2 The Ld. CIT(A) confirmed these additions. 2. Aggrieved with the action of Ld. CIT(A), the assessee is in appeal before the ITAT through the following grounds: "1. For that and under the facts and circumstances and in law the Ld CIT(A)-1 Delhi erred in upholding the contentions as well as order of assessment passed by the DCIT-Circle -1(2) Kolkata hence such act of authority below is not sustainable in the eyes of law; 2. For that and....
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....e is violation of Sec-10(a)(in) of the act against the payments made under the head of expenses of printing of diaries etc for Rs. 4,46,000/- disregarding the plea taken by the appellant and citations thereof is out of biasness, baseless, whimsical, arbitrary, and on bad faith and motive hence the act of such disallowance is liable to be quashed for the sake of justice: 6. For that and under the facts and circumstances of the case and in law the authority below erred in disallowing the expenses under the head of " Rental Expenses" and debited accordingly from accounts of Rs. 87,500/- as this expenses was incurred partly for providing the employees for present business purpose and partly for the purpose of assessee for running busin....
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....e records before us. Regarding the issue of payment amounting to Rs. 8,27,249/-. It is pertinent to extract the relevant portion from the Ld. CIT(A) orders: "5. In the 2nd and 3rd ground of appeal, the appellant has contended that the A.O. has acted arbitrarily by disallowing the service charges Rs. 8,27,249/- as there is no finding that the said claim was not incurred for the business purpose, as such his finding is completely arbitrary, unjustified and illegal. The contentions of the appellant have duly been considered. In the assessment order, the AO has discussed the matter in detail. The AO has observed that vouchers and ledger accounts of such payments were produced by the appellant during assessment proceedings. The AO obser....
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....ot allowable as business expenditure. 5.1 In view of the facts narrated above and in view of the findings and observations of the Hon'ble Calcutta High Court, the contentions of the appellant that the A.O. has acted arbitrarily by disallowing the service charges Rs. 8,27,249/- as there is no finding that the said claim was not incurred for the business purpose, as such his finding is completely arbitrary, unjustified and illegal cannot be accepted. I find no merit in the contentions of the appellant. The amounts paid to certain persons for getting payments released from Govt Departments cannot be termed as business expenditure and are not an allowable expenditure u/s 37 of the Act. All the contentions of the appellant in this r....