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TMI Blog2018 (3) TMI 1021X X X X Extracts X X X X X X X X Extracts X X X X ..... ribunal itself vide order dated 25/08/2016. 3. We have gone through the orders of the authorities below as well as the order of the Tribunal dated 25/08/2016, wherein the addition of Rs. 33,25,027/- so upheld by the CIT(A) was deleted by the Tribunal after observing as under:- 7. So far as the remaining material of Rs. 33,25,027/- is concerned, the plea of the assessee is that the worth value of the material at the time of use was not that of invoice value. The material at the time of use had reduced to the scrap value which was used by the assessee for its manufacturing activity and the value of the material used was taken at 'zero' cost. The profits from the corresponding sales have already been offered for taxation by the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... equent assessment years, however, no disallowance was made in those years. It was contended that assessee being in the business of manufacturing and export of power supplies used to visit foreign countries for making purchases from the customers abroad and the expenditure so incurred on travelling was only for the purpose of business. Accordingly, it was prayed that mere disallowance of part of the expenditure will not entitle the AO to levy penalty for concealment of income. 8. On the other hand, learned DR relied on the order of the lower authorities. 9. We have considered rival contentions and carefully gone through the orders of the authorities below. From the record, we found that the assessee manufactures different models of SMPS an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t Singapore and final customers of the assessee are mainly based in USA. The assessee had submitted details of foreign travel expenses vide letter dated 24 February 2006. The assessee had specified the period of visit and destinations visited. The places visited by these people included Singapore and various cities within USA, where various end customers of the assessee are located. Visits were also made to Shri Lanka and Japan for identifying new customers. The assessee also provided names of the customers visited, place of visit, persons with whom meetings, etc. were conducted and contact numbers of these customers. The assessee also submitted certain direct correspondences between the assessee and customers. These details have not been c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... every addition confirmed. We found that the assessee has made sufficient disclosure vide various submissions made to the AO at the time of assessment proceedings. The expenditure claimed by the assessee is accounted for in its books of accounts. The facts submitted by the assessee viz. dates and places of visit by the directors of the assessee have not been challenged by the AO or the appellate authorities. 12. As per record, we observe that all the facts were disclosed and the claim was made for deduction of travelling expenses. As per record the assessee has made a bonafide claim. The AO as well as CIT(A) have not challenged the genuineness / bonafides of the expenditure so incurred. The claim of the assessee is also supported by variou ..... X X X X Extracts X X X X X X X X Extracts X X X X
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