TaxTMI 
TaxTMI 
2025 (4) TMI 2064
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....er: "1. Whether the CIT(A) has erred in deleting the addition of Rs. 4,22,03,463/- without recognizing that the assessee is a company whose accounts have been prepared & audited by professionals and qualified Chartered Accountant and who is bound to prepare accounts & audit report on actual figures and not by taking hypothetical figures. 2. Whether the CIT(A) has erred in deleting the addition without recognizing that the onus to prove the genuineness of expenses debited in Profit & Loss account with documentary evidences lies on assessee and the assessee fails to provide documentary evidence on expenses claimed at Rs. 4,22,03,463/-. 3. The appellant craves leave, to add, vary, omit or substitute any of the afores....
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....contended that during the course of assessment proceedings as well as in the remand report proceedings, specific query was raised with respect to expenses incurred on the said event which was not produced by the assessee. The ld. DR pointed out that for the event managements, there is reference to an agreement but the assessee failed to produce the written agreement. The ld. DR further contended that the assessee failed to communicate details related to the event and its management. 6. Per contra, the ld. counsel for the assessee submitted that the entire revenue from the event organised in Norway and the entire expense of the event was accrued/borne by the Singaporean company M/s Studio SOS Production INC, Singapore. The assessee merely....
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.... Ltd 246 Comp Cas 180 2. CIT Vs. Shoorji Vallabhdas and Co. [1962] 46 ITR144 3. Godhra Electricity Co. Vs. CIT 4 SCC 530 4. CIT Vs. Excel Industries Ltd 13 SCC 459 10. We have heard the rival submissions and have perused the relevant material on record. We find that there is an entry by way of notes to the Account in the balance sheet with regard to receipt of Rs. 4.37 crore and expenses of Rs. 4.22 crore on account of conducting an event at Norway. The relevant extract from the Notes to Accounts under Revenue Recognition reads as follows: "The company, during the year, managed a Bollywood-themed event in Norway for a fee of USD 25,000. The company, in its books, has shown the total budget of the event....