ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. VIJAY DAIRY AND FARM PRODUCTS PRIVATE LIMITED, MUSIRI , TRICHY

आयकर अपीलीय अिधकरण, ‘ए’
यायपीठ, चे ई।
IN THE INCOME TAX APPELLATE TRIBUNAL
‘A’ BENCH: CHENNAI

ी एबी टी. वक
, ाियक सद एवं
एवं
एवं
एवं

ी मनोज कुमार अवाल, लेखा सद के सम

BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRIMANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER

आयकरअपीलसं./ITA No.483/Chny/2024
िनधारणवष/Assessment Year: 2019-20

The ACIT,
Central Circle-1,
Trichy.

v.
M/s.Vijay Dairy &
Farm Products Pvt. Ltd.,
Trichy-Thuraiyur Main Road,
Peramangalam,
Musiri Tk.,
Trichy-621 006. [PAN: AAACV 2113 N]
(अपीलाथ/Appellant)

(यथ/Respondent)

Department by :
Mr. Nilay Baran Som, CIT
Assessee by :
Mr. N. Arjun Raj, Advocate
सुनवाईक तारीख/Date of Hearing
:
29.01.2025
घोषणाक तारीख /Date of Pronouncement
:
19.03.2025

आदेश / O R D E R
PER ABY T. VARKEY, JM:

This appeal has been preferred by the Revenue against the order of the Learned Commissioner of Income Tax (Appeals), (hereinafter referred to as “the Ld.CIT(A)”), Chennai-19, dated 29.12.2023 for the Assessment
Year (hereinafter referred to as "AY”) 2019-20. 2. Brief facts as not the business of procu products. For AY 2019- income on 27.09.2019
thereto, a survey u/s.
referred to as ‘the Act‘
and the survey team is books of accounts and recorded the stateme
Director], Shri. S.C.
individuals of the asses u/s 143(3) of the Act d noted to have made ad of Rs.5,45,50,646/- un expenses incurred on Rs.52,62,942 holding it of Rs.30,23,496/- for expenses towards ren
Rs.2,76,784/- respectiv income of the assessee as returned by the asse
ITA No.483/Chny/
M/s.Vijay Dairy & Far
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ed are that, the assessee company uring, processing and selling of -20, the assessee company had file declaring total income at Rs.1,29,0
133A of the Income Tax Act, 196
) was conducted on 19.02.2019 at noted to have found certain discre d the Income Tax Return (ITR), f ents of Smt. VidhyaMadan Moh
Paneerselvam, [GM (Finance)] a ssee company. The AO in the asse dated 21.09.2021 for the relevant dditions on account of (a) unaccou nder Section 69A of the Act, (b) d n freezer boxes supplied to th to be capital in nature, (c) disallow want of supporting details, (d) d nt & professional fees of Rs.6
vely. The AO accordingly compu e at Rs.7,67,19,781/- instead of Rs essee. Aggrieved, the assessee prefe

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y is engaged in milk and milk ed its return of 06,110/-. Prior
61 (hereinafter ttheir premises, pancies in their for which they han [Executive and other key ssment framed
AY 2019-20 is nted purchases disallowance of eir agents of wance of salary disallowance of 6,99,803/- and uted the total s.1,29,06,110/- erred an appeal before the Ld. CIT(A) w
Revenue is in appeal be “1. The order of the erroneous on facts of th
2. The Ld.CIT(A) erre towards unaccounted p meaning of Sec.69A of quantified as difference
2.1 The CIT(A) erred contains the working p
Chilled Milk Registers(R assessee had not provid litres either during sur made addition by invoki
3. The Ld.CIT(A) err
Rs.52,62,942/-incurred are revenue in nature, assessee company and hence to be considered
4. The CIT(A) erred del to Rs.30,23,496/- claim centers, without apprec documents like break u salary, date of credit in transaction.
5. For these grounds a that may be raised dur learned CIT(Appeals) m restored.
3. Ground No.1 is adjudication.
4. Ground No.2 is addition of Rs.5,45,50
milk/ unaccounted exce
ITA No.483/Chny/
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who was pleased to delete the addit fore us on the following grounds: - learned Commissioner of Income Tax (App he case and in law.
d in deleting the addition of Rs.5,45,50,646
purchase of milk/unaccounted excess stock wi f the Act, being the value of 20,60,848 litres in purchases during the survey.
in failing to appreciate that the loose sheet prepared during survey, in which quantity as RCM) and purchase as per SAP were compared ded any satisfactory explanation in respect of 20
rvey or assessment proceedings, thus the AO ing provision u/s. 69A.
red in deleting the disallowance of expe on providing freezer boxes to agents holding t without appreciating that the freezer belonge d could be taken back on termination of age as capital in nature.
eting in the disallowance of salary expenses am med to be made to staff of Village level C ciating that the assessee had not furnished su p of name of beneficiaries, account number, am nto their bank accounts to ascertain the genuin nd any other ground including amendment of ring the course of the appeal proceedings, the may be set aside and that of the Assessing O s general in nature which doesn against the action of the Ld.CIT(A ,646/- made towards unaccounte ess stock made u/s.69A of the Act b

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tions. Now, the peals) is 6/ made ithin the s of milk t No.122
per Raw and the 0,60,848
O rightly enses of that they ed to the ency and mounting
Collection pporting mount of eness of grounds order of fficer be ’t require any A) deleting the ed purchase of being the value of 20,60,848 liters of m during the course of sur
4.1
The facts as no Authorized Officer in th difference of 20,60,848
and the quantity of milk assessee, and that this Manager (finance) as w assessee, in the course the purported loose she course of survey, was n the instructions of the assessee brought to not in the course of survey typed by the office staff need time to reconcile relevant extracts of his
“I understand as has been typed i
This voluminous from SAP also ha

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milk which was quantified as differen rvey.
oted are that, the AO had obser e course of survey had found that litresof milk between the loose shee k purchased as maintained in the S discrepancy could not be explained well as the Executive Director of the e of assessment, is noted to have eet Sl. No. 122 which was impoun not found from their premises, but w survey team by their office staff tice the statement given by the Exe wherein he clearly stated that this l f at the instance of the survey team e this voluminous data with the statement, is noted to be as under:
you just explained that the RCM data men in excel during the course of this survey data typed has to be verified, and the da s to be validated”

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nce in purchase rved that, the there existed a et in Sl No. 122
SAP data by the by the General e assessee. The explained that, ded during the was prepared at f. For this, the ecutive Director oose sheet was m, and that they
SAP data. The - ntioned about by our staff.
ata extracted

erefore explained that, this loose- workings prepared by the investigati was already existing at the time of xcel sheet was typed/prepared fro ound in the course of survey, w tive details of milk purchased from hin the factory from one batch to a s excel sheet had no rational basis etails, for the reason that the i aken as purchases from suppliers further sought to corroborate th e was no difference in physical inv data found at the time of surve y unaccounted purchases was found mporaneous facts, according to hat this loose-sheet was unreliable urchases as was being wrongly alle et no. 122. The AO however is erthought explanation and accordin e of 20,60,848 liters of milk, by ad by made an addition of Rs.5,45,50

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-sheet was not ing officers and f survey. It was om the manual which not only m suppliers, but another. It was as it contained inter-batch/unit s in this excel eir explanation entory of stock ey and also no d at the time of the assessee, and that there eged by relying noted to have ngly added the dopting average
0,646/- u/s 69A of the Act. On appeal th is before us.
4.3
The Ld. DR appe explanation given by the 122 was an afterthough
Per contra, the Ld. AR s
4.4
Heard both the pa difference in quantitati
(‘RCM’) as found noted per SAP data. We find submitted that, this loo survey but was typed in of the survey team, an reliable and hence could us that, when the sur several stock- registers level. Since these regi wanted to reconcile the for which they required details mentioned in all purposes, which was ca
ITA No.483/Chny/
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he Ld. CIT(A) deleted the same. No earing for the Revenue has conte e assessee denying the contents of ht and therefore the addition ought supported the order of the Ld. CIT(A arties. The issue-in-dispute before u ve details of the purchases of Ra on loose sheet no. 122 vis-à-vis th d that, before the Ld. CIT(A), the ose-sheet no. 122 was not found in n an excel sheet by an office staff nd had therefore urged that its con d not be viewed adversely. The Ld. A rvey was conducted at the assess were found to be manually maintai isters were voluminous, the inves noting’s in these manual registers d one floor staff to simply type t these registers in an excel sheet, fo arried out by the floor staff in a shor

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ow the Revenue ended that the loose sheet no.
t to be upheld.
A).
us relates to the aw Chilled Milk he purchases as e assessee had n the course of at the instance ntents were not AR explained to see’s premises, ned at the floor stigating officer with SAP data, he quantitative or their working rt span of time.

He further explained th contents of these manu excel sheet at the time verifiable from the time sheet, which was printe course of survey. We fin in light of the statemen survey, which is being e
“I understand as has been typed i
This voluminous from SAP also ha
4.5
Having regard to records, we countenanc this loose-sheet to be u
“6.2.7
..Thus sheet relied upon course of survey the staff at time course of survey not verified prope
6.2.8
The un upon by the AO prepared by the A is the comparativ survey team. On as incriminating m
ITA No.483/Chny/
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hat, the floor staff didn’t apply the ual registers, but simply typed the of survey. According to the Ld. AR e-stamp which would be discernible ed and seized by way of loose-sheet nd this explanation of the assessee t of the Executive Director recorded extracted again below, - you just explained that the RCM data men in excel during the course of this survey data typed has to be verified, and the da s to be validated”
o the above and the facts as di ce the following findings of the Ld.
nreliable, :- from the above fact it can be inferred th n by the AO is nothing but the data prepare by comparing the SAP data and RCM data of survey. The RCM data prepared by sta has not revealed the true affairs, since t erly.
ndersigned is of the view that the loose in the assessment order is not the on Appellant during the course of its business.
ve figures prepared during the course of s account of this, the character of “loose sh material, has lostits significance.”

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eir mind to the details onto an R, this fact was from this excel t no. 122 in the to be plausible, d at the time of ntioned about by our staff.
ata extracted iscernible from CIT(A) holding hat the loose ed during the a prepared by aff during the the data was sheet relied e which was Obviously, it survey by the heet” to treat

above Ld. CIT(A)’s findings, the hat, the noting’s in this excel sheet hich was discernible from the noting ed in the assessment order. Havin his argument that the figures me y contain details of purchases from tch transfers taken from the factory le to reconcile these figures with pu per, incomplete and non-verifiable d the unreliability of the above loos ed from the fact that, there was no k as per SAP data found by the surv t, the survey authorities didn’t find hich suggested that, the assessee ha ade any unaccounted purchases in uge quantity of unaccounted purcha n form of difference in physical sto sh sales etc. would have been fou of any such incriminating eviden s plea that, the above referred loose

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e Ld. AR also contained inter g’s on the excel ng perused the ntioned on this m suppliers, but y registers and urchases as per data.
se-sheet is also discrepancy in vey authorities.
d even a single ad effected any cash. Had the ases during the ock, noting’s of und in survey.
nce or details, e-sheet was not reliable and that the purchases outside the b
4.8
Apart from the following finding that, t was legally untenable, facts of the present cas follows: -
“6.2.11
In the section of sectio unaccounted pu
Whereas it can be owner of any mo not recorded in t survey team. Fur regard and in th made any findin satisfactory. Thu inappropriately in the difference in stock. Accordingl treating the diffe stock is not susta
4.9
In view of the ab of Ld. CIT(A) deleting purchases of RCM. Acco
5. Ground No. 3 o deleting the disallowanc made by the AO holding
ITA No.483/Chny/
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assessee had not effected any books of accounts.
above, we also countenance the he invocation of Section 69A of the as it did not have any application se. The relevant findings taken note instant case the AO has invoked the on 69A of the Act to treat the alleged d rchase / unaccounted excess stock in e seen that the Appellant company was no ney, bullion, jewellery or other valuable ar the books of accounts of the Appellant com rther the AO has not called for any explan he absence of any such explanation, the gs that the explanation offered in his o us the undersigned is of the view that nvoked the provisions of section 69A of the stock as unaccounted purchase / unacco ly it is considered that the addition mad erence as unaccounted purchase / unacco ainable both on legality and merits.”
ove, we see no reason to interfere the addition made on account o ordingly, this ground of Revenue sta f the Revenue is against the order ce of sales promotion expenses of g it to be capital in nature. The fac

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y unaccounted e Ld. CIT(A)’s e Act by the AO n on the given e of by us is as provisions of difference as n the order.
ot found to be rticle which is mpany by the nation in this AO has not pinion is not the AO has e Act to treat unted excess e by the AO unted excess with the order of unaccounted nds dismissed.
r of Ld. CIT(A)
Rs.52,62,942/- ts as noted are that, during the relev
Rs.52,62,942/- towards comprised of the cost o the assessee. Accordin assessee and could be particular vendor ends a and not revenue exp purchase of freezer box
5.1
On appeal, the Ld by observing as under:
“6.3.6
The un
Appellant. As sub the expenditure i same was put in disputed that the From the facts it selling vendors, t the same is left agent will return
Appellant has los arguing that the practice, it is a k sales to the Appe such freezers the at the selling poi freezer boxes be when the contrac vogue, once the lost its control ov
6.3.7
The Ho
CIT-1980 124 ITR pertains to the c
ITA No.483/Chny/
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vant year, the assessee had de s sales promotion expenditure, whic of freezer boxes provided to the re g to the AO, these freezer boxes e taken back if and when the c and therefore, it was in the nature enditure. The AO thus disallowe es holding it to be capital in nature.
d. CIT(A) is noted to have deleted th
- dersigned has carefully examined the subm bmitted by the Appellant there can be no d ncurred by the appellant in purchase of fre nto business activities of the Appellant. I e freezer are lying at various selling points t can be seen that oncethe freezers are the Appellant has no control over the said with the agents. It can also be appreci n back the used freezer to the Appellan st its control over the product, there can b freezers are the assets of the Appellant kind of incentive / gift given to the Agent ellant as well as the agent. In addition in th ere is every possibility that any non-sold ite int. In such scenario the findings of the A elong to the company and shall be taken ct with a particular endsis contrary to th freezers are handed over to the Agent, t ver such asset.
on’ble Apex Court in the case of Empire Ju
R 1 (SC) has held that to treat a particular haracter of revenue or capital, there does

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ebited sum of h the AO found etail vendors by belong to the ontract with a of capital asset d the cost of he disallowance mission of the dispute about eezer and the It is also not s at all times.
given to the freezers and ated that no nt. When the be no point in Company. In s to promote he absence of em will perish
AO that these n back if and he practice in the Appellant te Co Ltd Vs.
r expenditure s not exist an all-embracing fo problem; no touc decided on its ow operation in respe
6.3.8
The un picture of the ope by the Appellant seen from the eye a turnover of Rs.
towards freezer gross turnover. T
Appellant which a contention that in able to sell the pr back of the produ result in loss. Wh is of the view tha expenditure and Appellant has los agents. In this b contention of the of this, all the g treated as allowe
52,62,942/- treat
5.2
Aggrieved, the Re
5.3
Heard both the p noted that, the assess supply of milk & milk
Accordingly, when the vendors for further sale the vendors to store the spoilt/damaged. These vendors to facilitate th
ITA No.483/Chny/
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rmula which can provide a ready solu chstone has been devised and that every ca wn facts keeping mind the broad picture ect of which the expenditure has been incu ndersigned has taken into consideration eration in respect of which the expenditure t, while doing so naturally the expenditu e of the appellant. The appellant Company
106,33,55,523/- and claimed a sum of Rs boxes supplied to the agents which is 0
The AO has failed to look into the products are perishable items. The Appellant has pu n the absence of such a freezer, the agent roducts to the end consumer which may re uct. The returned product will have no valu hen this overall situation is considered, the at providing of freezer to agents can only cannot be taken as capital expenditu st its control once the freezers are handed ackdrop, the undersigned is not inclined t
AO to treat the amount as capital expendi grounds raised by the Appellant upon th ed and the AO is directed to delete the ad ted as capital expenditure for the AY 2019- evenue is now in appeal before us.
parties. From the material placed o see is engaged in the business o products, which by its very nature assessee supplies the milk & milk e to consumers, it also provides fr e said milk/milk products to prevent freezer boxes are therefore pr he business of the assessee, becau

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ution to the ase has to be of the whole rred.
n the broad was incurred re has to be has reported s.52,62,942/-
0.49% of the s sold by the t forward the ts will not be esult in return ue which may e undersigned be a revenue re since the d over to the to accept the iture. In view his issue are ddition of Rs.
20.”
on record, it is f processing &
e is perishable.
products to its reezer boxes to t it from getting rovided to the use as per the agreed terms, if the mi early than expected, th with the assessee, that the sales, as in the abse able to sell the product would increase by mani possession of the agent any major value, and boxes are seldomly ret therefore, we are of the these freezer boxes sup the assessee’s business capital field.
5.4
At this stage, it down judgment of Hon’
CIT (124 ITR 1) relie expenditure of enduring case, the Hon’ble Supr
Courts had evolved va and revenue expenditur accordingly held that, e
ITA No.483/Chny/
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lk/milk- products gets spoilt/damag he vendors wouldn’t pay for the sa t these freezer- boxes are imperat ence of the freezer- boxes, the age ts to the end-consumer and that th folds. These freezer- boxes are not ts/vendors and since individually th having regard to the wear & tear turned back to the assessee. On t e view that, the expenses incurred pplied to the agents/vendors are me s and doesn’t give the assessee an would be relevant to discuss the ’ble Supreme Court in the case ofEm ed upon by the Ld. CIT(A), wherein g nature, was repelled, in a great m eme Court noted that by decided rious tests for distinguishing betwe re, but no test is paramount or con very case has to be decided on its f

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ged or perishes ame. We agree ive to facilitate nts may not be he sales-returns ed to remain in hese are not of r, these freezer the given facts for purchasing eant to facilitate y advantage in principles laid mpire Jute Vs n the theory of measure. In that cases, that the een the capital nclusive. It was facts keeping in mind the broad pictur expenditure has been spelled-out and may expenditure is made no into existence or an adv expenditure can be tre revenue". However, the that, it would be misle benefit for business exp is noted to have accordi
"There may be c advantage, of e account and the t advantage of end case within the consider is the na only where the a would be disallow consists merely or enabling th business to be while leaving th be on revenue for an indefinite not a certain or and mechanica circumstances o
5.5
We find the decisi case of CIT v. Associa
ITA No.483/Chny/
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re of whole operation in respect incurred. One such test which w be relevant for our purpose w ot only once and for all, but with a v vantage for which enduring benefit eated as capital in nature and not e Hon’ble Apex Court in the same br eading to suppose that, in all ca penditure would be capital expendit ingly held as under: - ases where expenditure, even if incurred nduring benefit, may, none-the-less, be test of enduring benefit may break down. I during nature acquired by an assesses th principle laid down in this test. What is ature of the advantage in a commercial se advantage is in the capital field that the wable on an application of this test. If the y in facilitating the assessee's trading he management and conduct of the e carried on more efficiently or more he fixed capital untouched, the expend account, even though the advantage m e future. The test of enduring benefit r conclusive test and it cannot be app ally without regard to the particular of a given case."
(emphas ons rendered by the Hon’ble Suprem ated Cement Companies Ltd. (1

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of which the was specifically was "when an view to bringing of a trade, the attributable to reath cautioned ses securing a ture. The Court for obtaining on revenue t is not every at brings the s material to ense and it is e expenditure e advantage g operations assessee's e profitably diture would may endure is therefore plied blindly r facts and sis supplied) me Court in the 172 ITR 257), and Hon’ble Rajasthan
Industries (154 ITR 6
5.6
Applying the afore that, the impugned exp of the assessee, was nature, as there is no ad capital field. Rather, assessee's trading ope gainfully refer to the de of CIT Vs Pepsico Ind expenditure incurred o locations for advertisem nature, as it was meant not give any permanen enduring advantage in f
5.7
In light of the ab case, as discussed abo
CIT(A) holding the agents/vendors for stor nature. Accordingly, this ITA No.483/Chny/
M/s.Vijay Dairy & Far
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High Court in the case of CIT v
680) to be on the same lines.
esaid principle to the facts of this ca penses incurred on freezer boxes to rightly treated by the Ld. CIT(A) dvantage which has accrued to the the expenditure was incurred to erations. In support of our foreg ecision of the Hon’ble Delhi High Co dia Holdings Ltd (207 Taxman 5
on glow signs & neon signs insta ment of their products was held to t to facilitate the business of the as nt advantage in capital field, though future.
bove reasons and the given facts ove, we countenance the above f expenditure on freezer boxes ring the assessee’s milk products to s ground is dismissed.

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v. Anand Gum ase, we observe o facilitate sales as revenue in assessee in the o facilitate the oing view, we ourt in the case
5) wherein the lled at several be revenue in ssessee and did h there was an of the present findings of Ld.
s supplied to o be revenue in 6. Ground No. 4 ra action of deleting the d
The facts on records re accounts found that a salary paid to Village Le that, the salary had no and that the details of t payment was done, was AO therefore the amou unsubstantiated and ac
Ld. CIT(A) deleted the i in appeal before us.
6.1
Heard both the p business of processing a milks from several villa which is turn, is transpo employed staff at these is paid on monthly basi salary is paid in bulk i consolidated cheque/RT the accounts of the resp
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aised by the Revenue is against th disallowance of salary expenses of R eveals that, the AO while examinin bulk sum of Rs.30,23,496/-has be evel Collection Centers (‘VLCC’). Th ot been paid specifically to any ind the bank account of the individual p s not made available by the assesse nt debited by way of ‘VLCC staff sa ccordingly he disallowed the same.
impugned disallowance. Aggrieved, arties. It is observed that, the ass and selling milks. The assessee the ges, who transfer the raw milk to c orted to the factory. The assessee h village level procurement centers, s. As is commonly found in major i in form of a single debit to the Ba
TGS, and the Bank in turn, credits pective beneficiaries/employees. Th

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he Ld. CIT(A)’s
Rs.30,24,546/-.
g the books of een claimed as he AO observed dividual person person to which ee. According to alary’ remained
On appeal, the the Revenue is sessee is in the refore procures chilling centers, has accordingly to whom salary nstitutions, the ank, through a the salaries in is is a common practice adopted by administrative hassle employees each month.
assessee’s Bank, who payment of salaries details/KYC have alread bank book of such an salary expense is foun salaries of each employ common business pract single debit appearing i opposed to salaries b accounts of the emplo appreciated the factual
“6.4.4
The un
Appellant durin submitted befo paid by way of Manachallur Bra through bank submitted nam before the A.O.
the details of a Code. The A.O proof. It may be making a conso credited the a beneficiaries. T
ITA No.483/Chny/
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corporates these days, as it of drawing up several cheques
. Instead, effectively this task is ou receives the payment in bulk a to individual account of emplo dy been provided to the Bank. Acco assessee, one single consolidated d, as opposed to individual debits yee/s. The AO is noted to have misu tice and wrongly doubted the genu n bank statement by way of ‘VLCC being individually paid to the re yee/s. We find that, the Ld. CIT( matrix of the case by holding as und ndersigned has carefully examined the ng the course of Assessment Proce re the A.O. that the amount claimed consolidated cheque to M/s. AXIS Ba anch, to facilitate them to disburse to the respective beneficiaries. The e of the person to whom the salar
To substantiate this claim the Appellan mount paid, Account No., Name of th
. has simply disallowed this amount e appreciated that the expenditure was olidated payment to a bank and the b mount in the respective bank acco
This is the practice followed by all /2024 (AY 2019-20) rm Products Pvt. Ltd.

prevents the for individual tsourced to the nd effects the oyee/s, whose ordingly, in the debit towards s in relation to understood this uineness of the staff salary’ as espective bank
(A) had rightly der:- e issue. The eedings has salary was ank Limited, the amount e Appellant ry was paid nt submitted e Bank, IFS for want of incurred by bank in turn ount of the the major institutions in p
Appellant is abl
Account No., Ba suspect the tra there can be no expenditure un view of this, the salary expenses
A.O. is not sus raised by the A allowed, and t
Rs.30,23,496/-
6.2
We thus see no r
Ld. CIT(A) and accordin
7. In the result, appe

Order pronounced (मनोज कुमार अवाल
(MANOJ KUMAR AGGA
लेखासदय/ACCOUNTANT
चेई/Chennai,
दनांक/Dated: 19th March, 2
TLN
आदेशक ितिलिपअेिषत/Copy

ITA No.483/Chny/
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paying the salary to their employees e to identify the Name of the Individu ank Branch and IFS Code, there exist n nsaction. When the evidences are un o ground on the part of the A.O. to d less contrary findings are made in th e undersigned has considered that disa s claimed by the Appellant contempla stainable on merits. Accordingly, all t
Appellant upon this issue are hereby the A.O. is directed to delete the being the disallowance of salary.”
reason to interfere with the above gly dismiss this ground of the Reven eal filed by the Revenue is dismissed d on the 19th day of March, 2025, in ल)
ARWAL)
MEMBER (एबी टी.
(ABY T. VA
याियकसदय/JUDI
2025. to:
nai / Madurai / Salem / Coimbatore.

/2024 (AY 2019-20) rm Products Pvt. Ltd.

. When the ual, Amount, no ground to n-rebuttable, isallow such he order. In allowance of ated by the the grounds y treated as addition of findings of the nue.
d.
Chennai.
/-
वक
)
ARKEY)
CIAL MEMBER