V.C. Arunai Vadivelan v. ACIT (2021) 282 Taxman 90 (Mad.) (HC)

S. 37(1) : Business expenditure-10% ad-hoc disallowance-Transport charges-Self made vouchers-Matter remanded for de novo consideration for verification of all documents. [S. 145]

Court held that considering nature of transportation industry computer generated vouchers may not be issued by transporters unless they are an organization owning a large fleet. If Assessing Officer had any doubt with regard to genuinity of any voucher, he could have drawn sample vouchers and called upon assessee to establish its genuineness.  Since Assessing Officer made ad hoc disallowance without assigning any specific reason to a voucher or bunch of vouchers, matter was to be remanded for de novo consideration and assessment was to be redone after a thorough verification of all documents.  (AY. 2014-15)