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TMI Blog2022 (1) TMI 643X X X X Extracts X X X X X X X X Extracts X X X X ..... ss of the assessee and has produced the booking of tickets and other details to substantiate, we do not find why ad-hoc disallowance should have been made. Similarly with regard to miscellaneous expenses also, as noted above, these are petty expenses and mostly relating to telephone expenses, advertisement expenses etc. Such expenses could not be disallowed on ad-hoc basis especially in the case of a corporate entity. The adhoc disallowance made by the Assessing Officer and the ld. CIT (Appeals) are deleted. - Decided in favour of assessee. - I.T.A. No. 5352/DEL/2017 - - - Dated:- 6-1-2022 - Shri G.S. Pannu, President And Shri Amit Shukla, Judicial Member For the Assessee : Shri Satyen Sethi, Advocate; And Shri A. T. Panda, A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (iv) Donation 5,00,000 (v) Provision for doubtful loans advances 1,40,520 (vi) Municipal taxes paid 95,509 (vii) Total 44,57,411 5. Thus, only expenditure of ₹ 22,85,148/- was claimed, the break-up of which is as under:- Employee benefit expenses (i) Salary, wages and bonus 7,80,000 Other expenses (ii) Repair maintenance ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 22,85,148 6. The ld. Assessing Officer required the assessee to explain the purpose of travelling, which was claimed at ₹ 10,96,510/- and also the miscellaneous expenses of ₹ 1,87,663/- out of sums aggregating ₹ 2,83,172/-. The ld. Assessing Officer held that no vouchers have been produced for verification and the purpose for the visit in travelling account and other misc. expenses. Accordingly, he proceeded to make ad-hoc addition of ₹ 10,00,000/-. 7. The ld. CIT (Appeals) has confirmed the disallowance. The relevant observations of the ld. CIT (Appeals) are as under:- 5.1 The assessee has filed the ledger account of travelling and conveyance, showing expenditure of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not produce the details and /or vouchers before the AO, or during the appellate proceedings, and looking to the nature of income, the disallowance of ₹ 10,00,000/- out of expenditure claimed of ₹ 22,85,148/- is not found excessive or unreasonable. The appellant has placed reliance on a number of case laws to argue that it had to incur certain expenses to maintain its corporate identity. Those cases are clearly distinguishable as the question in this case is whether the expenses claimed had anything to do with the operation of the company at all. After careful consideration, the grounds of appeal nos. 1 and 2 are dismissed. 8. We have heard both the parties and perused the relevant material referred to before us. In so fa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... made investment of ₹ 27.21 crores in Great Eastern Energy Corporation Ltd. to off-load the assessee s investment. The observations and the findings of the Assessing Officer while making the disallowance, is purely based on surmises. If the assessee has stated that it had undertaken travelling for getting consultations with solicitors for litigation connected with the business of the assessee and has produced the booking of tickets and other details to substantiate, we do not find why ad-hoc disallowance should have been made. Similarly with regard to miscellaneous expenses also, as noted above, these are petty expenses and mostly relating to telephone expenses, advertisement expenses etc. Such expenses could not be disallowed on ad-ho ..... X X X X Extracts X X X X X X X X Extracts X X X X
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