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TMI Blog2019 (10) TMI 1521X X X X Extracts X X X X X X X X Extracts X X X X ..... n mentioned in the order that the additions are being made on account of non-furnishing of the requisite documentary evidence to substantiate the sale promotion, goods replaced and discount given to the Indian customers. For perusal of the Bench, assessee produced plethora of documents to support his contention. We are of the considered view that when the assessee has produced requisite documentary evidence before the AO, the addition was not required to be made on the ad hoc basis rather it should have been made, if any, on the basis of actual facts of the case. In these circumstances, we deem it necessary to remand the case back to the AO to decide afresh in the light of the documents relied upon by the assessee as well as in the light ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing assessment proceedings, Assessing Officer (AO) noticed that the assessee has not produced any evidence qua the cost of goods for sales promotion and cost of goods replaced to the tune of Rs.1,31,66,740/- and Rs.32,66,827/- respectively and reached the conclusion that as against the goods replaced in the preceding years worth of Rs. 19,53,457/-, assessee replaced cost qua the year under assessment to the tune of Rs.32,98,086/- which is raised by 68% as compared to the last year whereas sales have been increased to the tune of 19% only and also proceeded to hold that in the preceding year, cost of goods for sale promotion was Rs.64,81,403/- but during the year under assessment it was Rs.1,31,66,740/- which is increased by 104% and consequ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t of non-furnishing of the requisite documentary evidence to substantiate the sale promotion, goods replaced and discount given to the Indian customers. For perusal of the Bench, assessee produced plethora of documents to support his contention which are available at pages 45 to 193 of the paper book. 8. In view of the matter, we are of the considered view that when the assessee has produced requisite documentary evidence before the AO, the addition was not required to be made on the ad hoc basis rather it should have been made, if any, on the basis of actual facts of the case. In these circumstances, we deem it necessary to remand the case back to the AO to decide afresh in the light of the documents relied upon by the assessee as well ..... X X X X Extracts X X X X X X X X Extracts X X X X
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