Globizz Synergy Private Limited Vs ITO (ITAT Ahmedabad)
The two appeals concerned the same assessee and assessment years but arose from separate orders of the National Faceless Appeal Centre (NFAC), Delhi, dated 10.12.2025 and 12.12.2025. One appeal related to quantum proceedings under Section 143(3) of the Income Tax Act, 1961, while the other concerned penalty under Section 270A. Since the issues were interrelated, both appeals were heard together.
The assessee, a non-asset based logistics company founded in 2013, had declared total income of Rs. 1,51,63,830/-. The Assessing Officer disallowed the entire marketing expenses of Rs. 31,87,542/- for insufficient substantiation. The authorities below recorded that the assessee had furnished evidence in the form of self-made vouchers but had not furnished third-party invoices, bills, vendor agreements or details regarding the purpose of expenditure.
The expenses included petrol, food, refreshments, gifts, sponsorship, pamphlets, client visits and event sponsorship. The assessee submitted that its audited books reflected total revenue/turnover of Rs. 66,69,91,881/-, while the marketing expenses represented approximately 0.5% of the total revenue.
The ledger showed marketing expenses of Rs. 21,79,041/-, employee benefit expenses of Rs. 2,01,792/- and office expenses of Rs. 8,06,709/-. The office expenses included petrol, food, tea and coffee, refreshments, courier and other ancillary expenses. Marketing expenses related to exhibitions, client visits and fuel expenses reimbursed to employees travelling to different cities for client visits.
