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TMI Blog2019 (8) TMI 148X X X X Extracts X X X X X X X X Extracts X X X X ..... ontrary the material, opposed to the facts and equity and law. 2. That on the facts and in the circumstances of the case the ld. Lower authorities have erred were not justified in not allowing the all claim of various expenses are claimed by the appellant and therefore the following expenses may please be allowed. i.Rs. 7,32,106/- out of Rs. 29,28,424/- being 25% of traveling expenses. ii. Rs. 8,68,730/- out of Rs. 86,87,305/- being 10% of building repair expenses. iii. Rs. 85,730/- out of Rs. 857,300/- being 10% of repair and maintenance. iv. Rs. 2,60,355/- out of Rs. 1,46,68,471/- depreciation v. Rs. 1,78,527/- out of Rs. 1,78,527/- being 100% of gift and present expenses. vi. Rs. 2,69,724/- out of total interest claimed at ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ieved against this, the assessee is in appeal before this Tribunal. Ld. Counsel for the assessee reiterated the submissions as made in the written synopsis. For the sake of clarity, the submissions of the assessee are reproduced as under: 7. Ld. Counsel for the assessee submitted that the books of accounts of the assessee are duly audited. The expenditure is duly supported by the supporting evidences. Further, Ld. Counsel for the assessee submitted that entire disallowance/additions have been made on adhoc basis without considering the material on record. 8. On the Contrary, Ld. D.R. opposed these submissions and supported orders of the authorities below. 9. We have heard the rival submissions, perused the materials available on record a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he A.O. made disallowance on adhoc basis. In respect of both the disallowances, the revenue authorities have made purely on estimation basis. It is not a case where the assessee has inflated the expenses. Therefore, considering the totality of the fact, we restrict the disallowance to the extent of 5% of the total disallowance made in this regard. Another disallowance of gift and presents amounting to Rs. 1,78,527/-, it is stated by the Ld. Counsel for the assessee that the addition has been made purely on adhoc basis. It is stated that the A.O's allegation that vouchers were self-made and not reliable is not correct. It is stated that the vouchers specifying the nature and purpose were mentioned in the narration and bills/documentary evide ..... X X X X Extracts X X X X X X X X Extracts X X X X
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