Ad-hoc disallowance carried out in the assessment without specific findings vis-à-vis reasoning - onus...

Ad-hoc disallowance carried out in the assessment without specific findings vis-à-vis reasoning - onus to prove - Disallowance of deduction under Section 37(1) - Once the assessee is absolved in aforesaid terms, the onus is then shifted on revenue to prove negative litmus test, deprecating the GSP and explanation tendered by the assessee by clear findings on record. More precisely such exercise shall require before arriving at percentile / percentage to be applied for each of the expense (head o..... .....

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