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TMI Blog2025 (2) TMI 608X X X X Extracts X X X X X X X X Extracts X X X X ..... g expenses made by the AO and the 25% confirmed by the CIT(A) is accordingly sustained. Disallowance u/s 40(a)(ia) - reimbursement of expenses - assessee made TDS in respect of agency charges but being reimbursement has not made any TDS on such parties relying upon various judicial pronouncements & CBDT Circular No.715 dated 08.08.1995 - HELD THAT:- The assessee had availed services of clearing and forwarding agency for clearing of its goods from Customs and had to make payment of agency charges to the C&F Agent. Assessee also made payment of reimbursement of expenses incurred by C&F agency on behalf of the assessee like Freight Charges, Transportation charges, Customs duty etc. on actual basis. AR rightly relied upon the decision of Cons ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IT(A) may kindly be deleted." 3. The assessee Company is engaged in the trading business of different types of chemicals alongwith seals, stationery items, coils, ceiling and other accessories and import of the products as well as purchase of the products from the local markets and selling the same in local market and in foreign market on small scale basis. The assessee filed return of income for the Assessment Year (A.Y.) 2013-14 on 29.09.2013 claiming refund of Rs. 46,540/-. The case of the assessee was selected for scrutiny under Section 143(1) of the Income Tax Act, 1961. The statutory notices were issued and the assessee filed details as well as the submissions. After taking cognisance of the same, the Assessing Officer observed that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... travelling expenses was incurred for visit to China and that is for visit to one party M/s. International Chem Limited from whom the assessee had imported goods worth Rs. 36.53 Crores as against the total purchase by the assessee of Rs. 38.47 Crores during the year under consideration. The assessee has already submitted statement showing details of foreign traveling undertaken by various persons of Company as well as invoices/bills in respect of foreign travel expenditure. 6. The Ld. DR submitted that the CIT(A) after verifying the details only has restricted the expenditure to 25% which is a reasonable disallowance and thus relied heavily on the order of the CIT(A). 7. We have heard both the parties and perused all the relevant material ..... X X X X Extracts X X X X X X X X Extracts X X X X
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