9911796707
TMI Blog2019 (4) TMI 1017X X X X Extracts X X X X X X X X Extracts X X X X ..... f the assessee to deduct service tax while providing service to the customers. Therefore, it comes under the purview of business expenses and hence is rightly deleted by the CIT (A). Ground of Revenue s appeal is dismissed Disallowance of the amount debited under the head short and excess - HELD THAT:- The amounts debited under this head represented the pity difference in the balances of the debtors either on account of rounding off the balances or under recovery of such amount from debtors which were allowable as business expenditure u/s 36(1)(vii) of the Income Tax Act, 1961. Thus, the CIT(A) rightly deleted this addition. Disallowance of unexplained expenditure - HELD THAT:- The assessee before the Assessing Officer filed complete bill vise details along with copies of invoices received from the factory at the time of delivery of diesel as well as filed confirmed copy of its ledger account in the books of M/s Garg Road Lines along with copy of bank statement/duly reflect the payments made by the assessee on various dates of M/s Garg Road Lines for supply of diesels. All these relevant evidences were ignored by the Assessing Officer during the assessment proceeding. The CIT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hen the assessee concern signed an agreement with Consortium of CWG for providing electrical support for opening and closing ceremony of Common Wealth Games. But the facts are that the Assessee could only determine the exact amount payable to it when the R/A Bills were provided to it to, in turn, include it as income in its books of accounts. As per Accounting Standard 9 on revenue recognition issued by the ICAI, para 11 of the main principle inter-alia states if at the time of raising of any claim it is unreasonable to expect ultimate collection, revenue recognition should be postponed. The payment (Rs. 27,72,354/-) for the work done in the contracts with CPWD was made through the tenth RA Bill dated 13.11.2011. Thus, the Assessee included the income in its books of accounts as income credited for the AY 2012-13. Thus, the assessee has postponed the revenue recognition due to the reason that the exact amount payable was not determined and the expected time for receiving payment was also not definite. - Ground of assessee is allowed. Disallowance of business promotion expenses - HELD THAT:- The assessee provided tickets of the opening ceremony to both the customers and the empl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uments submitted under the said rule. CIT(A) rejected the application under Rule 46A of the Income Tax Rules, 1962, without commenting on the above-mentioned documents submitted to prove the identity, genuineness and creditworthiness of the transaction. Thus, it will be appropriate to remand back this issue to the file of the Assessing Officer and after taking cognizance of the documents in the form of additional evidence, the Assessing Officer should decide this claim accordingly. Needless to say the assessee be given opportunity of hearing by following principles of natural justice. Ground is partly allowed for statistical purpose. - I.T.A. No. 1710/DEL/2015, I.T.A. No. 1827/DEL/2015 And S.A No. 913/Del/2018 - - - Dated:- 14-3-2019 - SHRI N. K. BILLAIYA, ACCOUNTANT MEMBER AND MS SUCHITRA KAMBLE, JUDICIAL MEMBER For The Appellant : Sh. Salil Kapoor, Adv Smt. Pallavi Saigal, Sh. Sumit Lal Chandani For The Respondent : Ms. Nidhi Srivastava, CIT DR, Smt. Ashia Neb, Sr. DRs ORDER PER SUCHITRA KAMBLE, JM These two appeals are filed by the Revenue as well as the assessee against the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ellant alternatively claimed that there was no bar in recognizing income in respect of a new line of business on cash basis . 1.3. That the CIT(A) further erred in not appreciating that since there was hardly any probability of very recovery/ realization of the aforesaid amount and therefore, taxation of the aforesaid amount tantamount to taxable of notional amount as income . 1.4. Without prejudice, that the CIT(A) also failed to appreciate even if the aforesaid amount of ₹ 6,99,24,861, not recognized in the books, were to be taxed as income, then, equivalent amount ought to be allowed as deduction under section 36(l)(vii) of the Income Tax Act, 1961 ( the Act ). 2. That the CIT(A) erred on facts and in law in confirming the addition of ₹ 27,72,354 made by the assessing officer, being the alleged amount of contract revenue receivable by the appellant from Central Public Works Department ( CPWD ). 2.1. That the CIT(A) erred on facts and in law in not appreciating that the appellant had followed a consistent method of recognizing income from the aforesaid contract, which was always accepted by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... llowance to the extent of ₹ 3,68,579 (i.e., 1/10th of ₹ 36,85,792) made by the assessing officer on account of various expenses incurred by the appellant in the regular course of business. 7. That the CIT(A) erred in confirming levy of interest under sections 234B and 234D of the Act. 3. The assessee is a Private Limited Company and is engaged in the business of providing temporary infrastructure facility for events and exhibitions. A search and seizure operation u/s 132 of the IT Act, 1961 was conducted at the business premises of the assessee on 19.10.2010. The assessee company belonged to M/s PICO Deepali Overlays Consortium Group. The assessee filed its return of income declaring a total income of ₹ 2,03,93,170/- on 25.10.2011. The case of the assessee was taken up for scrutiny and notices u/s 143(2) and 142(1) along with a detailed questionnaire were issued and served upon the assessee. In response to the notices issued, the AR of the assessee attended the assessment proceedings from time to time and filed the required details and information. Thereupon, the assessment was competed in terms of order u/s 143(3) of the IT Act, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 14. Addition on account of disallowance of hire charges Rs. 62,33,080/- 4. Being aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A) partly allowed the appeal of the assessee. 5. Firstly we are taking up the Revenue s appeal. The Ld. DR in respect of Revenues appeal submitted that there are 5 grounds agitated by the Revenue in the present appeal. The assessee debited an amount of ₹ 15,50,903/- as interest on late payment of service tax under the head interest which is Ground No. 1 of Revenue s appeal. The Ld. DR submitted that the Assessing Officer has rightly rejected the said claim as it is the duty of the assessee to deposit the service tax deducted within the time allowed as per the provision of the Income Tax Act. The Ld. DR further submitted that the CIT(A) deleted this amount on the sole ground that interest charge for deleted payment of Sales Tax does not have the correct of penalty for an offence and hence allowable as deduction as its is merely compensation for money withheld. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 8. As relates Ground No. 2 relating to the addition of ₹ 6,488/- on account of disallowance of additional service tax. The Ld. DR relied upon the order of the Assessing Officer and submitted that the CIT(A) erred in deleting this addition. The Ld. AR relied upon the order of the CIT(A). 9. We have heard both the parties and perused the material available on record. The amount of service tax paid by the assessee was not in the nature of penalty but represented the tax which was not collected by the assessee from its customers and was paid out of its own debited and was thus allowable u/s 37(1) of the Income Tax Act, 1961. The amount was expanded by the assessee during the course of its business and it was wholly and exclusively for the business purposes. The expenses cannot be said that the same was not related to business of the assessee as it was the duty of the assessee to deduct service tax while providing service to the customers. Therefore, it comes under the purview of business expenses and hence is rightly deleted by the CIT (A). Ground No. 2 of Revenue s appeal is dismissed. 10. As related to Ground No. 3 relating to addition of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ences were ignored by the Assessing Officer during the assessment proceeding. The CIT(A) has rightly taken into account all the details filed by the assessee before the Assessing Officer and after verifying the same arrived at the right conclusion that the claim of the assessee is right as the purchase of diesel from the said party was genuine. The assessee has satisfied all the three elements of genuineness creditworthiness and identity of the parties, as per the provisions of the Income Tax Act. Therefore, there is no need to interfere with the findings of the CIT(A). Ground No. 4 of the Revenue s appeal is dismissed. 16. As regards Ground No. 5 of the Revenue s appeal relating to restricting the addition of ₹ 3,68,580/- (being 1/10th of ₹ 36,85,792/-) from ₹ 7, 37,158/- (being 1/5th of ₹ 36,85,792/-) made by the Assessing Officer on account of expenses claimed in profit and loss account. The Ld. DR submitted that the Assessing Officer has rightly made 1/5th addition on account of expenses claim being profit and loss account. The Ld. DR further submitted that the assessee could not provide the name and address of the person to whom cash pay ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cted to modify the disallowance accordingly, while giving effect to this order. The CIT(A) has rightly observed that the assessee fail to produce evidence to substantiate the assets in questions were exclusively use for business purpose only. There was no explanation given to cash as well but after considering the overall effect. The CIT(A) has rightly disallowed 1/10th of the total motor car expenses including depreciation and telephone expenses claim by the assessee. Hence, Ground No. 5 of the Revenue s appeal is dismissed as well as Ground No. 6 of the assessee s appeal is dismissed. 19. Now we are taking up the assessee s appeal. As regards to Ground No. 1 relating to low declaration of contract amount in the contract with M/s Pico Deepali Overlays Consortium group amounting to ₹ 6,99,24,861/-, the Ld. AR submitted that in respect of M/s Deepali Design Exhibits Private Limited (DDEPL) was a part of the consortium known as 'PICO Deepali Overlays Consortium which was formed by an agreement dated 19.12.2009 for the purpose of obtaining contract from Organizing Committee - Common Wealth Games 2010. However, on 01.06.2010 an addendum ag ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rk executed by the Assessee. Thereafter the Assessee instituted a suit in the Hon ble High Court of Delhi against the consortium for the rendition of accounts of the Consortium and for the recovery of ₹ 6,99,24,861 /- as per the contract with the Consortium. Pursuant to the abovementioned suit filed, assessee was granted a preliminary decree in the money suit for ₹ 4,19,05,956/- with interest at 9% per annum vide order dated 18.07.2017 passed by the Hon ble High Court of Delhi (the claimed amount was ₹ 6,99,24,861/-). Thereafter, Assessee company received ₹ 4,19,05,956 during F.Y. 2017-18 which was accounted for in the books of account of the Assessee as it income for AY 2018-19. Copy of income tax return, computation of income, balance sheet, Profit Loss account along with ledger account for AY 2018-19 as well as party wise details of hire charges was submitted before the Assessing Officer. While passing the Assessment order dated 21.03.2013, the AO observed that by filing the suit as well as by raising bills and rendering services against the consortium, the Assessee had claimed a right to receive the income. The AO made the addition on the basis that th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the same vests with the Assessee whereby the payer of the income become lawful debtor of the Assessee. The Hon ble Supreme Court in the case of CIT v. Excel Industries Ltd. [2013] 358 ITR 295/219 has even held that An income accrues when it becomes due but it must also be accompanied by a corresponding liability of the other party to pay the amount. Only then it can be said that for the purposes of taxability said income is not hypothetical and it has really accrued to the assessee . The Hon ble Supreme Court in the case of CIT Vs. Balbir Singh Maini [2017] 398 ITR 531 (SC) have observed that the income accrues when it becomes due but it must also be accompanied by a corresponding liability of the other party to pay the amount. Only then it be said that the purposed of taxability that the income is not hypothetical and it has really accrued to the assessee. The Ld. AR relied upon the following decisions:- S. No. Judgment Citation 1 CIT(A) Vs. Shoorji Vallabhdas Co. (Page NO. 19-21 of CLC) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITO Vs. Prakash Road lines Corpn ITA No. 2070 of 1988 (Cal) 21. The Ld. AR submitted that the assessee has upon receiving the amount during AY 2018-19 has paid the tax thereon and has disclosed the same in the return of income for AY 2018-19. The only dispute is in regard to the subject assessment year in which tax is payable. However, this stand of the Revenue needs to be considered with the fact that in the succeeding assessment year, the return of income filed by the assessee (in which the amounts forming a part of the present addition were offered to tax) tax stands already paid. The Ld. AR submitted that assessee was granted a part decree in the money suit for ₹ 4,19,05,956/- with interest at 9 Percent per annum (the claimed amount was ₹ 6,99,24,861/-). The said judgment and decree was partly executed on 08.03.2018 pursuant to which assessee company has received ₹ 6,60,02,809/-. The Ld. AR submitted that assessee Company has disclosed the said receipt in the income tax return for AY 2018-19 and paid tax thereon. The Ld. AR also submitted that as per Accounting Standard 9 on revenue recognition issued ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d two method of accounting for different types business has been followed in succeeding years. Further, without prejudice, it is prerogative of the Assessee to choose a method of accounting for a particular business. Reliance is placed on the judgment of Maruti Securities Ltd. Vs. ACIT (ITA No. 468/Hyd/2009) the tribunal in the said case has held that where the assessee is following the mercantile system of accounting, it is only accrual of income that is chargeable to tax. When certain uncertainties exist regarding determination of amount or is collectability, revenue shall not treat it as accrued until collection. Strictly, without prejudice to the above submission, the Ld. AR submitted that entire contract value is treated as income under the mercantile system, then the amount of ₹ 6.99 not recoverable under the current disputes and exigencies (which is pending before judicial forum) could be treated as bad debt under section 36(1)(vii) of the Act. The cash system adopted for CWG project is cash neutral and not detrimental to the revenue. The Ld. AR further submitted that Assessee company has upon receiving the amount during AY 2018-19 has paid the tax thereon and has disc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... able, the Assessee wrote numerous letters to the Consortium asking them to render the accounts for the ascertainment of the quantum of amounts received by the Consortium against the work executed by the Assessee. However, the Consortium did not render any accounts to the Assessee. The Assessee also wrote a number of letters to the OCCWG-2010 to ascertain the amount paid to the Consortium in relation to the work executed by the Assessee. Thereafter the Assessee instituted a suit in the Hon ble High Court of Delhi against the consortium for the rendition of accounts of the Consortium and for the recovery of ₹ 6,99,24,861 /- as per the contract with the Consortium. Pursuant to the abovementioned suit filed, assessee was granted a preliminary decree in the money suit for ₹ 4,19,05,956/- with interest at 9% per annum vide order dated 18.07.2017 passed by the Hon ble High Court of Delhi (the claimed amount was ₹ 6,99,24,861/-). Thereafter, Assessee company received ₹ 4,19,05,956 during F.Y. 2017-18 which was accounted for in the books of account of the Assessee as it income for AY 2018-19. From the records and the agreements it can be seen that these facts narrate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing the subsequent year i.e. AY 2012- 13 by following the consistent method of accounting. Taking into account that: * the assessment was done as per the MB, * the payments were released on the basis of the R/A Bills, and * the amount payable to the Assessee was ascertained as per the percentage of work completed The Ld. AR submitted that the Assessee could only determine the exact amount payable to it when the R/A Bills were provided to it to, in turn, include it as income in its books of accounts. As per Accounting Standard 9 on revenue recognition issued by the ICAI, para 11 of the main principle inter-alia states if at the time of raising of any claim it is unreasonable to expect ultimate collection, revenue recognition should be postponed. The Ld. AR further submitted that the payment (Rs. 27,72,354/-) for the work done in the contracts with CPWD was made through the tenth RA Bill dated 13.11.2011. Thus, the Assessee included the income in its books of accounts as income credited for the AY 2012-13. The AO, based on the fact that the Assessee followed the Mercantile System of Accounting, used the same approach wh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Court order also discussed the case of S. D. Sassoon and Co. Ltd. Vs. Commissioner of Income-tax, Bombay City, [1955] 1 S. C. R 313, that followed Rogers Pyatt Shellac Co. V. Secretary of State (1925) I.L.R 52 Cal 1. The Calcutta High Court in the case of CIT(A) Vs. Simplex Concrete Piles India (P) Ltd. 179 ITR 8. Accounting Standards laid down by ICAI also lays down that when the realization of income is virtually certain- then the related asset is not a contingent asset and its recognition is appropriate. Here again what is true for recognition of a payment is also true for recognition of income under mercantile system of accounting. In the case of CIT(A) Vs. Shrimati Singari Bai In another case on a similar issue the matter was decided in favour of Revenue in the case of Delhi Transco Ltd. in ITA No 2483/Del/2013 for AY 2005-06. Submissions regarding provisions of section 145(2), Section 5 of Income Tax Act, case laws on mercantile method of accounting and accounting principles regarding recognition of revenue. The Ld. DR submitted that these submissions of the Revenue may be considered along with oral submissions in this regard and the grounds of appeal raised by assesse may ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th the customers and the employees. The expenditure incurred was bona-fide. The ledger account for the said expenses showed that the amount was incurred for the purchase of opening ceremony tickets of the CWG-2010. The AO decided that Assessee failed to establish that the business purpose in incurring the said expenses. Thus, the AO made an addition of ₹ 15,50,000/- in the income of the Assessee. The CIT (A) upheld the addition made by Assessing Officer. It is therefore, submitted that the aforesaid business expenses were incurred by the Assessee in the normal course of its business, which are allowable deduction under section 37(1) of the Act. The expenditure was necessary for carrying on the business more efficiently and for all future business opportunities. In that view of the matter, the aforesaid expenses are allowable as deduction. It is also humbly submitted that the contract was still in existence even after the opening ceremony concluded as the contract of the assessee included both the opening as well as closing ceremony. In the below mentioned case it was observed that incurring of business promotion/ publicity expenditure wherein the expenditure has been incurred ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... us, the Assessing Officer as well as CIT(A) was not correct in disallowing the said expenses. Ground No. 3 is allowed. 31. As regards to Ground No. 4, relating to addition on account of scrap sale of ₹ 3,35,58,732/- (Rs. 1,42,48,577/-, ₹ 1,91,90,514/- and 1,19,641), the Ld. AR submitted that Assessing officer made this addition on estimated basis on account of assumed residential value of the items. During the year under consideration Assessee has claimed expenditure on purchase of the above items and same was duly recorded in profit and loss account. The said material was utilized in executing the contractual work for CWG 2010 at various sites. The material was primarily used as raw material throughout in the process of erecting, constructing, installing/renovating the structures and fittings. Hence, the original form of raw materials purchased underwent complete/substantial change in its form and size as it was cut/modified/altered as per the requirements of the structure/work. Assessing Officer made the abovementioned addition on the ground that the purchase made by assessee of several items were of such nature that either they have multiple use or ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 01/-. The AO with regard to Tenting Material Fabric estimated the value of scrap to be 50% of the expenditure on purchase by the Assesee i.e ₹ 1,16,34,835/- and made an addition of Rs. ₹ 58,17,417/-. As these electrical items were of a capital nature, their residual value was determined to be 46% like the other electrical items. Thus, the total addition by the AO on the basis of the scrap value of all the aforementioned was of ₹ 3,35,58,732/-. On appeal, the CIT (A) agreed with the reasoning of the AO and confirmed the addition made by the AO. It is humbly submitted that Search and seizure operation u/s 132 of the Act was conducted at the business/residential premises of the Assessee on 19.10.2010. However, no documents were found during the search with respect to scrap sales. Therefore, there was nothing on record to show that sales of scrap outside the books of accounts were made. In this regard, we submit that the AO has not found even iota of evidence to establish that the scrap was sold for a value otherwise as recorded in the books of accounts. Also, no reason has been given for not accepting the value recorded in the books for scrap sale. That there was no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd can only be sold as scrap after dismantling. Also, the scrap of electrical fitting, items and accessories majorly comprises of plastic material and metal residue, which has little realizable value. The Ld. AR relied upon the judgment of the ITAT, Delhi in the case of ACIT Vs. M/s Sikka Papers Ltd. (ITA No. 899/D/2012) wherein it has been held that addition in relation to sale of scrap would not sustain without pointing out any discrepancy in bills and consumptions as well as estimation of scrap value. The ITAT, Ahmedabad in the case of DCIT Vs. Heavy Metal Tubes (ITA No. 294/Ahd/2010) has held that the Assessee had given all the details for generation of scrap and parties to which the scrap was sold. And in absence of any enquiry by the AO, the addition on sale of scrap on estimate basis without pinpointing any defect in the books of accounts of the Assessee cannot be sustained. Further, the ITAT, Delhi in the case of ACIT Vs. M/s Richa Company (ITA No. 3502 3503/Del/09) has also held that adhoc addition on sale of scrap without anything to show that the sale of scrap was outside the books of accounts and any information had been suppressed by the Assessee, in absence of a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ect of the used material, at the best of its ability in these stressful circumstances and was able to fetch ₹ 5 crores which has been duly entered in the books of accounts. The Ld. AR submitted that copies of names of the parties to whom scrap material was sold were given during the course of Assessment proceedings vide letter dated 11.03.2013 as mentioned above. The Ld. AR further submitted that the AO while making the addition on account scarp sale stated that the same was due to market value. However, copy of such market report is not available with the assessee neither has the AO reproduced a copy of the same while passing the Assessment order. The market enquires conducted by the AO were never confronted to the assessee. The AO has not conducted any further enquiry on his own, therefore, the addition made on account of scarp sale cannot sustain. 35. As regards the addition made by AO on the basis of deemed residual value, the Ld. AR submit that his action is grossly unjustified. The AO has made the addition on estimated basis whereas the actual realized value of scrap was recorded in the books. 36. The Ld. DR relied upon the Assessment Ord ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nnot be wholly consumable and made an addition of ₹ 11,60,774/- lacs. The AO with regard to Purchase of pipes, iron sheets, other misc items estimated the value of scrap to be 60% of the expenditure on purchase by the Assessee i.e. ₹ 44,36,002/- which amounted to ₹ 26,61,601/-. The AO with regard to Tenting Material Fabric estimated the value of scrap to be 50% of the expenditure on purchase by the Assesee i.e ₹ 1,16,34,835/- and made an addition of Rs. ₹ 58,17,417/-. As these electrical items were of a capital nature, their residual value was determined to be 46% like the other electrical items. Thus, the total addition by the AO on the basis of the scrap value of all the aforementioned was of ₹ 3,35,58,732/-. This entire addition though based on evidence produced by the Assessee during the Assessment proceedings, the Assessing Officer has not taken into account all the relevant evidence while determining the addition on the scrap sale. Besides that the Assessing Officer has not given any basis as to estimation of these sale of scrap. Thus, the reasoning to arrive at this addition is not properly given by the Assessing Officer. The CIT(A) also ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce the Assessee was prevented by the sufficient cause from producing the abovementioned documents before the Assessing Officer during assessment proceedings. In his remand report, the Assessing Officer requested for non-admission of additional evidence adduced by the Assessee without appreciating the facts of the case and the documents submitted under the said rule. CIT(A) rejected the application under Rule 46A of the Income Tax Rules, 1962, without commenting on the abovementioned documents submitted to prove the identity, genuineness and creditworthiness of the transaction. The CIT(A) has failed to appreciate that M/s Arun Khullar Co. is a regular service provider to the Assessee. Arun Khullar Co. provides services in relation to stage set-up and design, etc. for the various events handled by the Assessee in the normal course of business. In this regard reliance is placed on the decision of the Tribunal in the case Dhanna Ram Garg v. Income-tax Officer, Ward 25(1), New Delhi (ITA No. 2216/D/2011). The Assessee submitted ledger accounts for AY 2009-10 to 2014-15. It is pertinent to note that such ledger accounts were also submitted during the course of assessment proceedings ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... adduced by the Assessee without appreciating the facts of the case and the documents submitted under the said rule. CIT(A) rejected the application under Rule 46A of the Income Tax Rules, 1962, without commenting on the abovementioned documents submitted to prove the identity, genuineness and creditworthiness of the transaction. Thus, it will be appropriate to remand back this issue to the file of the Assessing Officer and after taking cognizance of the documents in the form of additional evidence, the Assessing Officer should decide this claim accordingly. Needless to say the assessee be given opportunity of hearing by following principles of natural justice. Ground No. 5 is partly allowed for statistical purpose. 42. As regards to Ground No. 6 in respect of general disallowance of ₹ 3,68,579, the Ld. AR submitted that during the year under consideration, Assessee has claimed following expenditure in respect of its business activities: i. Motor vehicle running - ₹ 14,53,527/- ii. Telephone expenses - ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
