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TMI Blog2019 (10) TMI 659X X X X Extracts X X X X X X X X Extracts X X X X ..... ortedly enhancement of income is wholly unwarranted, without giving any notice for enhancement of income to the assessee therefore, is insupportable in law and on facts and deserves to be set aside. 3. That the additions/disallowance sustained by the learned CIT(A) are unjustified, contrary to the principles of natural justice and equity and in any case much too high and excessive. 4. That any other relief or reliefs as may be deemed fit on the facts on record, be granted." 2. At the outset, Learned A. R. invited my attention to the fact that the appeal filed by the assessee is delayed by 721 days and our attention was also invited to copy of application for condonation of delay. Our further attention was invited to copy of affidavit s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the interest was excessive. Learned A. R. in this respect submitted that complete details of the payees along with their confirmations were filed and the rate of interest from market was around 18% only as the loans from market is always unsecured and therefore, it carried a higher rate of interest and therefore, the disallowance should not have been made. 3.2 Regarding the third addition out of advertisement expenses, Learned A. R. submitted that the authorities below have made the disallowance as the notices issued by the Assessing Officer u/s 133(6) had returned back. Learned A. R. argued that while making the disallowance, the authorities below have ignored the fact that the payments were made through banking channels. He further ar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n ad hoc basis. Before learned CIT(A), the assessee submitted that no defect was pointed out by the Assessing Officer in any of the vouchers and had relied on a number of case laws. Learned CIT(A), on the basis of submissions, restricted the disallowance of 10% to 5% and also upheld a part of certain disallowances. The learned CIT(A) had also not cited any reason for partly confirming the additions and partly allowing the additions. In view of the above, the disallowances sustained by learned CIT(A) are not in order and therefore, we allow the appeal of the assessee." Therefore, the addition sustained by learned CIT(A) on the basis of ad hoc disallowance is deleted. 6. Now coming to the addition on account of advertisement expenses, I f ..... X X X X Extracts X X X X X X X X Extracts X X X X
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