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TMI Blog2019 (2) TMI 1200X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee has failed to produce any evidence in support of its contention, the learned Counsel for the assessee has filed a list of the customers amongst whom the IPL Cricket match tickets have been distributed. DR opposed the admission of this evidence at this stage and submitted that, if the Tribunal were to consider the same, then the said evidence should be remanded to the file of the AO. This list was admittedly not produced before any of the authorities below. Therefore, we treat it as additional evidence and admit the same and remand the issue to the file of the AO to verify whether these parties were the customers of the assessee and whether they were given the alleged IPL seasonal tickets. Assessee’s appeal is treated as allowed for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s 37(1) of the I.T. Act and should be allowed as such. 3. However, the AO was not convinced with the assessee s contentions and held that the assessee failed to produce any cogent evidence that the tickets were distributed amongst its business related persons. Holding that it is necessary for the assessee to support his claim for deduction u/s 37(1) of the Act, for the failure of the assessee to furnish any details, the AO disallowed the same and brought it to tax. Aggrieved, assessee preferred an appeal before the CIT (A), who confirmed the order of the AO holding it to be application of income and not business expenditure. Aggrieved by the order of the CIT (A), the assessee is in appeal before us by raising the following grounds of app ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ubmissions in support of its claim u/s 37 of the Act are that it has purchased the IPL cricket match tickets to distribute them amongst its long standing customers to garner their goodwill and improve its business relations and therefore, it is its business expenditure. According to us, this is a plausible and acceptable submission. This is akin to distribution of gifts or articles on special occasions to the customers and such expenditure has been held to be business expenditure. Further, in reply to Revenue s contention that the assessee has failed to produce any evidence in support of its contention, the learned Counsel for the assessee has filed a list of the customers amongst whom the IPL Cricket match tickets have been distributed. Th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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