Disallowance cannot be made of expenditure not claimed as deduction in profit & loss account

Brief of the Case

ITAT Delhi held In the case of Sunaina Tower Pvt. Ltd. vs. ACIT that the material issue is that the said expenditure was never claimed as business expenditure, the occasion to make a disallowance of the same does not arise. On this fact there is no dispute as admittedly the expenditure was not claimed as an expense by the assessee and consequently has not been routed through its P&L A/c. In the circumstances, the occasion to make an addition of the same by way of a disallowa

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