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TMI Blog2018 (12) TMI 270X X X X Extracts X X X X X X X X Extracts X X X X ..... Ludhiana is against law and facts on the file in as much as she was not justified to uphold the action of the Ld. Assessing Officer in making disallowance of Rs. 1 0,89,016/- on account of education sponsorship expenses. 2. That she was further not justified to uphold the action of the Ld. Assessing Officer in making disallowance of Rs. 2,69,050/- out of foreign travelling. 2. The ld. AR inviting attention to the written submissions extracted in para 4.1 by the CIT(A) submitted that the issue has been decided without referring to relevant facts. Reading from para 4.2 of the order, it was his submission that the CIT(A) has ignored the fact that in support of the expenditure copy of the Board Resolution passed in the meeting held on 15.0 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lution [A Copy Enclosed] dated 15.03.2010 was passed by the appellant, wherein, it has been resolved that: "The Company Will Bear all the Expenses Including Tuition and Fees, Living Expenses and all other required expenses and all other required expenses in U.S.A. After Completion of his study, he will Serve the Company at Least for a Period of 2 Years." Furthermore. Sh. Sumit Bansal, a Son of a Director Sh. Viiav Kumar Bansal is working with the appellant since April, 2013. A Proof of Factory Attendance Register and Monthly Salary/Wages Payment Register for the Month of April, 2013 and March, 2014 respectively is enclosed, substantiating the above fact. 3. The ld. Sr.DR, on the other hand, vehemently opposing the said prayer sought ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce for the business of appellant company. I also find in agreement with the reasoning of the assessing officer that in the past also the appellant company has not sponsored any of other states student for pursuing higher education abroad . In view of the fact and the decisions relied upon by the assessing officer during the course of assessment proceedings I am in complete agreement with the view of the assessing officer as the AO held that these expenses were incurred under the head of education sponsorship but are of purely of personal expenditure. The assessee has also, failed to prove that the expenditure was wholly and exclusively for the purpose of business. The reliance is placed on the decision in the case of NATCO exports Private L ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , awarded the Certificated Copy of a Certificate is Enclosed] in Entrepreneurship and Innovation at West Lafayette in the State of Indiana in Management in recognition of the fulfillment of the Requirements of the Certificate Program in Management. The skills in Entrepreneurship, and, to undertake new Innovation were Learnt through the said course, so that Sh. Sumit Bansal could apply the same in creating value of the Organization." 4.1 On a reading of the finding of the CIT(A) which has been extracted in an earlier part of this order, it is evident that these submissions on facts have not been addressed by the CIT(A). Thus, we find that the conclusion arrived at in the impugned order wherein on facts the submissions are not addressed can ..... X X X X Extracts X X X X X X X X Extracts X X X X
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