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INCOME TAX APPELLATE TRIBUNAL (INDORE BENCH)
Shri Vijay Pal Rao, J, Shri B.M. Biyani, ACJ
SOM DISTILLERIES PVT. LTD. BHOPAL – Appellant
Versus
ITO-1(3) BHOPAL – Respondent
| Table of Content |
|---|
| 1. background of cross-appeals concerning income tax assessments. (Para 1 , 2 , 3) |
| 2. arguments regarding disallowance of donation expenses. (Para 4 , 5 , 6 , 8 , 10) |
| 3. court’s reasoning on ad hoc disallowances not backed by evidence. (Para 14 , 15 , 16 , 18) |
| 4. evidentiary requirements and permissible grounds for disallowance of claims. (Para 28 , 35 , 36) |
| 5. conclusion on the adjudications and disposition of appeals. (Para 43) |
ORDER
Per Bench:
Feeling aggrieved by appeal-order dated 30.05.2023 passed by learned Commissioner of Income-tax (Appeals)-3, Bhopal [“CIT(A)”] which in turn arises out of assessment-order dated 30.12.2016 passed by ITO, 1(3), Bhopal [“AO”] u/s 143(3) of the Act for AY 2014-15, the assessee and revenue both have filed the captioned cross-appeals.
2. Since these are the cross-appeals by parties against the same order of lower-authorities, they were heard together at the request of parties and are being disposed of by this consolidated order for the sake of convenience, brevity and clarity.
3. The background facts leading to present appeals are such that the assessee is a company engaged in the business of manufacture of spirit, IMFL & country liquor.
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