Held, that the assessee had not shown expenditure in its profit and loss account. Since no such expenditure had been claimed by the assessee against the Revenue for the year and this fact remained undisputed at the end of both the parties, the disallowance made under section 40(a)(ia) of the Act was uncalled for. (AY. 2012-13, 2014-15)
ACIT v. Parag Fans and Cooling System Pvt. Ltd. (2021) 86 ITR 598 (Indore)(Trib.)
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Settlement of loan shown in profit and loss account-No expenditure was claimed-No disallowance can be made.