Kushal Virendra Tandon v. CIT (2021) 91 ITR 610 / (2022) 215 TTJ 630 (Mum.)(Trib.)

S. 37(1) : Business expenditure-Ad-hoc disallowance of 20 percent of expenses-Not sustainable.

Held that the assessee had produced the requisite details, viz., bills, vouchers, and payment details to substantiate the genuineness and veracity of the expenses, and also to drive home the fact that they had been incurred wholly and exclusively in the normal course of his profession. The lower authorities had neither pointed out which of the expenses claimed by the assessee were not supported by documentary evidence nor earmarked those items whose genuineness they doubted. There was nothing discernible from the records to show which of the expenses had not been incurred by the assessee wholly and exclusively for the purpose of his profession. As the disallowance of expenses was made in an arbitrary and ad hoc manner hence deleted.  (AY.2014-15)