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| The Tax Publishers2019 TaxPub(DT) 5046 (Kol-Trib) INCOME TAX ACT, 1961
Section 143(3)
Ad hoc disallowance based on suspicion and conjectures without AO rejecting assessee's books under section 145(3) could not be sustained when identical expenses had been allowed in preceding years and there was no change in facts and circumstances during the relevant year.
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Assessment - Ad hoc disallowance of 20% of travelling expenses - Non-rejection of books -
Assessee claimed deduction of travelling expenses. AO disallowed 20% tereof on the ground that assessee might be inflating its expenses. Held:Ad hoc disallowance based on suspicion and conjectures without AO rejecting assessee's books under section 145(3) could not be sustained when identical expenses had been allowed in preceding years and there was no change in facts and circumstances during the relevant year.
REFERRED : Radhasoami Satsang v. CIT (1992) 193 ITR 321 (SC) : 1992 TaxPub(DT) 858 (SC).
FAVOUR : In assessee's favour.
A.Y. : 2013-14
INCOME TAX ACT, 1961
Section 28
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