Disallowance of expenditure on mere presumption & assumption is unsustainable

DCIT Vs Curosis Healthcare Private Limited (ITAT Jaipur) ITAT Jaipur held that revenue has simply disallowed the expenditure in view of CBDT Circular no. 05/2012 dated 01.08.2012 without establishing the violation thereof. Accordingly, disallowance merely on presumption and assumption is unsustainable in law. Facts- The case of the assessee was re-opened and accordingly, notice u/s 148 of the Act had been issued. In response, the assessee filed submission stating that the assessee filed ROI against the notice u/s 148 of the Act declaring total income of Rs. 49,81,330/- and requested to furnish...