9911796707
TMI Blog2023 (4) TMI 847X X X X Extracts X X X X X X X X Extracts X X X X ..... aken the following grounds of appeal: "1. The Ld.CIT(A) has erred in law as well as facts of the case in deleting the additions of disallowances towards the salary/remuneration of Rs. 17,40,000/- and Rs.12,60,000/- paid to Treasurer and Secretary of the Trust and Rs.3,00,000/- to Shri Kala Choudhary for hiring of bus and Rs.8,40,000/- for hostel Building Rent to M/s Aadya Bhasker Enterprises Private Limited from the income of Trust which were found excessive and unreasonable under sub-section (3) of Section 13 of the Income Tax Act, 1961 during the course of assessment proceedings and were added by the A.O. in the assessment order passed u/s 143(3) of the Income Tax Act, 1961 on 17/11/2017. 2. Any other ground will be taken at the time ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e aforesaid amount of salary was not reasonable. Even he has observed that the aforesaid persons were rendering full time services to the trust, earlier they were rendering service without taking any compensation for a number of years. Thereafter, during the financial year 2010-11, the trust resolved to start payment of salary to the aforesaid two persons who were rendering full time services to the trust. Further, in respect of disallowance of expenditure of bus hiring charges and hostel building rend, the ld. CIT(A) has observed that the bus hiring charges and hostel building rent were essential for travelling and accommodation facility provided to the students by the school. He observed that these activities were fundamental to the fulfi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and facts has merely concluded by stating that he has not found the explanation of the appellant satisfactory. On the other hand, the appellant has submitted complete details of the manner and reason for which it was decided to pay the salary to these persons. Further there is a basic logic to the appellant contention that the salary / remuneration paid is in line with what would have been paid to newly employed professionals having similar experience and qualification. Even otherwise the salary paid to these persons is permissible as per the provisions of the Act. Accordingly, I am inclined to accept the contention of the appellant that remuneration / salary paid to the persons by the society is reasonable and thus the disallowance is d ..... X X X X Extracts X X X X X X X X Extracts X X X X
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