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TMI Blog2017 (6) TMI 1312X X X X Extracts X X X X X X X X Extracts X X X X ..... ess persons. To presume that such small business people would have waited for more than 24 months for getting their payments is beyond preponderance of probability. Assessee was having a net profit of ₹ 19,39,154/- for the relevant previous year and a turnover of ₹ 9,46,63,745/-. Hence, there was no reason to postpone he payment to small parties for a period of 24 months. In my opinion, mere production of self vouchers and PAN will not be sufficient to believe an expenditure, which otherwise show by itself as quite against all reasonable probability. In such circumstances,lower authorities had every reason to disbelieve the claim and make the disallowance. - Decided against assessee. - I.T.A. No. 928/Mds/2017 - - - Dated:- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessees submissions before the ld. Commissioner of Income Tax (Appeals) were as under:- 1. Details of freight charges payable showing the details of payment made to such lorry owners and also details of the lorry registration number and PAN number of the lorry owner. 2. Payment vouchers for lorry freight charges paid . Ld. Commissioner of Income Tax (Appeals) sought a remand report from the ld. Assessing Officer. The ld. Assessing Officer in his remand report dated 01.02.2017, stated as under:- 1. During the course of scrutiny assessment it was seen that the assessee has shown lorry expenses payable amounting to D21,12,000/-. During the course of scrutiny assessment, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Authorised Representative strongly assailing the orders of the lower authorities submitted that PA number of each of the lorry owners were given. According to him, in the nature of the business of the assessee, payments were required to the made in cash. Further, according to him, the vouchers, though they were self made could not have been rejected without pointing out the defects in it. As per ld. Authorised Representative the disallowance had to be deleted. 5. Per contra, ld. Departmental Representative supported the orders of the authorities below. 6. I have perused the orders and heard the rival contentions. What I find is that the sum of ₹ 21,12,000/- was shown by the assessee as lorry hire charg ..... X X X X Extracts X X X X X X X X Extracts X X X X
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