Disallowance on adhoc basis for personal element without evidence cannot be upheld

New Delhi Tyre House Vs ACIT (ITAT Delhi) In this case a Ground  is on account of confirmation of disallowances out of telephone tours, and other expenses including depreciation on the car stating that involvement of the personal element of the partners of the firm cannot be ruled out. Both the lower authorities have confirmed the disallowances on that account.  On careful consideration and after hearing both the parties we find that the ld AO has made an ad hoc disallowances on this expenditure without pointing out any element of such personal expenditure. During the course of assessment, p...