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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 ..... om such brokerage /commission has been paid for the business of the assessee. In the absence of specific details, the AO was left with no choice but to make adhoc disallowance of the expenditure. CIT(A) deleted the addition as in his opinion, there was no loss to the Revenue. We do not find any justification in this findings of the 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. - Decided in favour of revenue - I.T.A. No. 6124/Mum/20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the explanation 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 ₹ 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 earning commission income. The AO went on to disallow 25% of the expenses so claimed and made an addition of ₹ 75,91,967/-. 4. The assessee carried the matter before the Ld. CIT(A) and reiterated its claim. The assessee further filed details of expenditure incurred by India Infoline Ltd. and allocated to the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was left with no choice but to make adhoc disallowance of the expenditure. The Ld. CIT(A) deleted the addition as in his opinion, there was no loss to the Revenue. We do not find any justification in this findings 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 order of the Ld. CIT(A) and restore that of the AO. 9. In the result, the appeal filed by the Revenue is allowed. Orde ..... X X X X Extracts X X X X X X X X Extracts X X X X
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