Onus to justify balance claim of expense on Assessee when he admits part of the same is excessive

 This court is of the opinion that the impugned order is unreasoned and has blindly accepted the Commissioner (Appeals)’s logic that propriety demands that the assessee’s surrender –restricted to Rs. 50 lakhs should be accepted. The expenses claimed were Rs. 1 crore. Once the assessee admitted that Rs. 50 lakhs was claimed excessively, the onus of showing that the balance Rs. 50 lakhs was a justified expenditure lay upon it. The assessee did not discharge that onus; the assessing officer was therefore justified in bringing in to tax that expenditure.

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