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TMI Blog2018 (5) TMI 126X X X X Extracts X X X X X X X X Extracts X X X X ..... teraction is restricted to social platforms. As regards son/s, he is an outsider to the business, at least for the relevant years. As for the later year (A.Y.2014-15),AR clarified that the son/s had joined business, and which may perhaps led to the acceptance of the assessee’s claim for that year (at 80%). The nexus of the impugned expenditure with the business for the years under reference is tenuous and, in the least, not total. In other words, the expenditure bears a significant component of personal (non-business) element. As the assessee may stand to derive some business benefit from such social intercourse and, further considering that the son/s has joined business subsequently, indicating a business purpose as well, we consider i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in the appeals under consideration relates to disallowances under the head of T.A. Conveyance. The Assessing Officer while framing the assessment order, disallowed an amount of ₹ 4,59,184/- (which was claimed by the assessee in lieu of expenditure under the head of TA Conveyance) , on the ground that the expenses related to the foreign travels of the family members alleged to have been borne by the assessee company and claimed as expenses can not be considered genuine, because foreign visit of the family members are the private visits which have been impliedly sponsored by the company and expenses are debited quite knowingly that these are not business related expenses and which are not liable to be allowed as deduction and moreov ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ts which are part of record. The Ld. A R further submitted that in the present case there are no changes in relevant facts during the years under consideration and AY 2014-15. Foreign Travelling Expenses of the wife/s and sons/s of the directors has been made in AY 2014-15 and this fact has been duly accepted by the Revenue. Therefore, the Revenue is precluding from taking a contrary view on same facts by disallowing the entire foreign travelling expenses of the wives of the directors. In addition to the aforesaid submissions, the assessee has also filed details of the foreign travel expenses. 6. We have gone through with the facts and circumstances of the case and also rival submissions of the parties, although the Assessing Officer in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er to the business, at least for the relevant years. In fact, for the later year (A.Y.2014-15), the ld. AR clarified that the son/s had joined business, and which may perhaps led to the acceptance of the assessee s claim for that year (at 80%). The nexus of the impugned expenditure with the business for the years under reference is tenuous and, in the least, not total. In other words, the expenditure bears a significant component of personal (non-business) element. As the assessee may stand to derive some business benefit from such social intercourse and, further considering that the son/s has joined business subsequently, indicating a business purpose as well, we consider it proper to restrict the disallowance to 40% of the impugned expend ..... X X X X Extracts X X X X X X X X Extracts X X X X
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