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TMI Blog2014 (5) TMI 231X X X X Extracts X X X X X X X X Extracts X X X X ..... number of persons to whom discount was offered, some of them also had given notarised affidavit - it directed to treat only the part of income as unexplained expenses - both the CIT(A) and the Tribunal adjudged the issue based on factual matrix – thus, no substantial question of law arises for consideration – Decided against Revenue. - Tax Appeal No. 151 of 2014 - - - Dated:- 31-3-2014 - Akil ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... holding the order of the CIT(A), restricting the disallowance of Rs.33,19,203/to Rs.59,000/without appreciating that in spite of the fact that the AO carried out verification of payments only in the cases of payees proposed by the assessee, the genuineness of the said payments could not be proved by the assessee? (iii) Whether on the facts and in the circumstances of the case and in law, the Tr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce examined the material on record. 3. We notice that though questions framed are more than one, essentially it concerns restricting the disallowance of Rs.33,19,203/to Rs. 59,000/in respect of expenditure under the provisions of Section 37(1) of the Act in the following factual background: 4. The assessee company is dealer of Hero Honda company. The assessee claimed discount expenditure of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... It noticed that the assessee had advertised the exchange offer in the newspaper and the commission earned from ICICI Bank was also disclosed. Out of the total number of persons to whom discount was offered, some of them also had given notarised affidavit. Cumulatively, it directed to treat only the part of income as unexplained expenses. 6. When challenged before the Tribunal, it concurred wit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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