The Assessing Officer disallowed 30 per cent of the staff welfare expenses on an ad hoc basis without recording any specific finding that any particular expenditure was not incurred wholly and exclusively for the purposes of business. The Tribunal held that such ad hoc disallowance was unsustainable and upheld the deletion made by the Commissioner (Appeals). (AY. 2014-15 & 2015-16).
SIEL Ltd. v. Dy. CIT (LTU) (2025) 123 ITR 599 / 173 taxmann.com 278 (Delhi)(Trib.)
S. 37(1) : Business expenditure-Staff welfare expenses-Ad hoc disallowance without identifying non-business expenditure-Deletion justified.
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