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

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