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TMI Blog2014 (7) TMI 1301X X X X Extracts X X X X X X X X Extracts X X X X ..... This appeal by the Revenue is preferred against the order of the Ld. CIT(A)-34, Mumbai dt.18.07.2011 pertaining to A.Y. 2008-09. 2. The sole grievance of the Revenue is that the Ld. CIT(A) erred in deleting the addition of 25% of unverifiable expenses amounting to Rs. 75,91,967/-. 3. The assessee is in the business of distribution of insurance policies. The return was filed on 27.9.2008 decla ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion offered by the assessee is not fully acceptable as merely furnishing a certificate from M/s. India Infoline Ltd that the expenses made by them include an amount of Rs. 3.03 crores have been allocated to the assessee". The AO further observed that no such agreement has been brought on record by the assessee. The AO further observed that the assessee must have incurred certain expenditure for ea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The Ld. Departmental Representative strongly supported the findings of the AO. 7. The Ld. Counsel for the assessee reiterated what has been submitted before the lower authorities and in particular before the Ld. CIT(A). 8. We have carefully perused the orders of the authorities below. It is an undisputed fact that the expenditure has been incurred by India Infoline Ltd on day today basis. It i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s of the Ld. CIT(A) as the issue before him was whether the expenditure claimed by the assessee are reasonable and sufficient for its business. The findings of the Ld. CIT(A) is accordingly erroneous since India Infoline has allocated the expenditure on estimated basis, we do not find any error in the findings of the AO who disallowed the expenditure on adhoc basis. We, accordingly, set aside the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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