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TMI Blog2023 (8) TMI 279X X X X Extracts X X X X X X X X Extracts X X X X ..... It is true that during the course of assessment proceedings itself the assessee has explained that repairs and maintenance expenses were incurred by it on its own vehicles and not on hired vehicles. Explanation of the assessee was supported by bills/vouchers. It is true that the Assessing Officer has neither pointed out any defect nor any infirmity in the explanation of the assessee. Considerin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of ht Assessing Officer and upholding the following additions: (i) Foreign travel expenditure Rs. 4,09,690/- (ii) Repair maintenance @ 20% [Adhoc disallowance under Transport Segment] Rs. 73,93,304/- (iii) Repair and maintenance @50% [Adhoc disallowance under Sanitization Segment] ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rs. 1,89,04,401.00. The assessee was asked to furnish complete details. The assessee submitted details. On perusal of the same, the Assessing Officer noticed that the assessee has deducted tax at source on expenses of Rs. 20,22,126/- and no TDS has been deducted on balance expenses of Rs. 1,68,82,275/-. 6. The assessee was asked to substantiate its claim. 7. The assessee explained that repai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by vouchers and the Assessing Officer neither expressed her appreciation nor dissatisfaction. The ld. counsel for the assessee further stated that it is eligible for deduction u/s 80IA of the Act and, therefore, any disallowance of expenses would not make in difference in itself, as the enhanced profit would become eligible for deduction u/s 80IA of the Act. 12. Per contra, the ld. DR suppor ..... X X X X Extracts X X X X X X X X Extracts X X X X
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