9911796707
TMI Blog2023 (1) TMI 1017X X X X Extracts X X X X X X X X Extracts X X X X ..... elf made - HELD THAT:- From the perusal of said vouchers, we find that the said vouchers mention the volunteer centre ID, the amount paid, and the signature of the volunteer on the date of payment. AR submitted that the names of the volunteers are not mentioned to maintain anonymity regarding the identity of the volunteer and instead the ID No. is mentioned in the record -this manner also safeguards the interest of the pharmaceutical company, whose drugs are tested. On a careful perusal of these vouchers, it is evident that the same cannot be called self-made, since these vouchers also contain the signatures of different volunteers acknowledging the receipt of payment in cash on different dates. In absence of any other allegation, we fi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... te and/or change all or any above grounds on or before the date of hearing. 3. The brief facts of the case are: The assessee is a private limited company and is engaged in the business of drug analysis, clinical trials, and other research activities. For the year under consideration, the assessee filed its return of income on 29/11/2014 declaring a total income of Rs.56,11,463. The return filed by the assessee was selected for scrutiny and statutory notices under section 143(2) and section 142(1) of the Act were issued. The Assessing Officer ( AO ) vide order dated 23/11/2016 passed under section 143(3) of the Act assessed the total income of the assessee at Rs.1,04,46,340 under normal provisions of the Act. The learned CIT(A) vide imp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... necessary details, we find no infirmity in the impugned order passed by the learned CIT(A) upholding the disallowance of 10% of the office expenses claimed by the assessee. As a result, ground No. 1 raised in assessee s appeal is dismissed. 7. The issue arising in ground No. 2, raised in assessee s appeal, is pertaining to the addition of 20% of the drug analysis expenses. 8. The brief facts of the case pertaining to this issue are: During the assessment proceedings, it was observed that the assessee has debited expenses related to drug analysis amounting to Rs.1,48,36,511. From the details filed by the assessee, it was noticed that the expenses claimed are not fully supported by bills and vouchers and all the expenses are incurred in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on the date of payment. The learned AR submitted that the names of the volunteers are not mentioned to maintain anonymity regarding the identity of the volunteer and instead the ID No. is mentioned in the record. It was also submitted that this manner also safeguards the interest of the pharmaceutical company, whose drugs are tested. On a careful perusal of these vouchers, it is evident that the same cannot be called self-made, since these vouchers also contain the signatures of different volunteers acknowledging the receipt of payment in cash on different dates. In absence of any other allegation, we find no basis for confirming the disallowance upheld by the learned CIT(A). Accordingly, we direct the AO to delete the disallowance in resp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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