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Issues involved:
The issues involved in this judgment are: 1. Addition made by the AO for a specific amount. 2. Disallowance of expenses on account of Deepawali expenses and conveyance expenses. Issue 1: Addition made by the AO for a specific amount The appellant, during assessment proceedings, received a certain amount from Pritam Industries and claimed that a portion of it was paid to other parties as part of a joint venture. However, the AO found that the transaction was more in the nature of professional fees rather than a joint venture. The CIT(A) confirmed the addition made by the AO, emphasizing that the arrangement did not qualify as a joint venture as claimed by the appellant. The CIT(A) also noted discrepancies in the amount offered for taxation by the appellant and the payments made to other parties. The tribunal upheld the orders of the revenue authorities, stating that the appellant failed to provide sufficient evidence to establish the nature of the receipts from Britannia Industries. Consequently, the addition made by the AO was deemed appropriate, and the CIT(A)'s order was confirmed. Issue 2: Disallowance of expenses on account of Deepawali expenses and conveyance expenses The AO disallowed a portion of the expenses claimed by the appellant for Deepawali and conveyance, citing a personal element in the expenditure. The CIT(A) agreed with the disallowance. However, upon further review, the tribunal found that the AO's decision lacked specific reasons for assuming a personal element in the expenses. The appellant argued that the expenses were incurred solely for business purposes. As a result, the tribunal decided to delete the disallowance of the expenses related to Deepawali and conveyance. Consequently, the appeal of the assessee was partly allowed.
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