CIT v. Ayesha Hospitals P. Ltd.

292 ITR 266High Court2007#6446 most cited
18

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2024.

Sections most often in play

Section 143(3)Section 260ASection 263

Judgments citing CIT v. Ayesha Hospitals P. Ltd.

HI-STYLE INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CORP CIRCLE 2(2)/CIT(A), CHENNAI

In the result, the appeal filed by the assessee is allowed

ITA 910/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Aug 2024AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.910/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 Hi-Style India Private Limited, Vs. The Deputy Commissioner Of 1652 G, 2Nd Avenue, Anna Nagar, Income Tax, Chennai 600 040. Corporate Circle 2(2), Chennai. [Pan: Aacch2545L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Babu Peram, C.A. ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 14.08.2024 घोषणा की तारीख /Date Of Pronouncement : 21.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 06.02.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2014-15. 2. The Assessee Raised 2 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration Is Whether The Ld. Cit(A) Is Justified

For Appellant: Shri Babu Peram, C.AFor Respondent: Ms. R. Anita, Addl. CIT
Section 143(3)Section 260ASection 263

…accepted by the Revenue, but, as per direction under section 263 of the Act, the Assessing Officer disallowed the expenditure in part. The ld. AR drew our attention to the decision of the Hon’ble Madras High Court in the case of CIT v. Ayesha Hospital P. Ltd. 292 ITR 266 (Mad) and argued that the Hon’ble High Court of Madras confirmed the order of the Tribunal in holding the expenditure incurred towards painting, re-laying of the damaged floors, partitions, etc. are revenue expenditure. Further, he drew our attention to the decision of the Hon’ble Supreme Court in the case of CIT v. Madras Auto Services P. Ltd. 2…

M/S SWANMANDIR JEWEL DESIGNER PRIVATE LIMITED ,TUMKUR vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1 , TUMKUR

In the result, the appeal filed by the assessee is partly allowed

ITA 141/BANG/2018[2012-13]Status: DisposedITAT Bangalore10 Aug 2021AY 2012-13

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessment Year: 2012 – 13

For Appellant: Shri Ravishankar S.V., A.RFor Respondent: Shri Kannan Narayanan, D.R
Section 32

…see, the same has to be treated as revenue expenditure, according to the Revenue, the same shall be treated as capital II expenditure. Whereas, the Tribunal by relying on the decisions of our High court reported in (i) CIT v. Ayesha Hospitals (P.) Ltd. [2006] 292 ITR 266 (Mad) and (ii) ThiruArooran Sugars Ltd. v. Dy. CIT [,2013]32LIR 324/213 Taxman 90 (Mag,)/31taxmann.com 3 (Mad.), held the expenses incurred as revenue expenditure and accordingly allowed deduction on account of the same. For better appreciation, para 5.3 of the order of the Tribunal is extracted hereunder: "5.3. We have heard both the parties and…

M/S. ASPECT RESEARCH & MANAGEMETN P. LTD.,,NEW DELHI vs. ITO, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 3204/DEL/2015[2007-08]Status: DisposedITAT Delhi05 Mar 2020AY 2007-08

Bench: Shri Amit Shukla

For Appellant: Shri Rohit Jain, Adv. & Shri AdityaFor Respondent: Shri Saras Kumar, Sr.D.R
Section 143(3)Section 144Section 40

…way India Enterprises: 346 ITR 341 (Del) CIT vs. Escorts Finance Ltd. 155 Taxman 559 (Del) CIT vs. HI Line Pens (P) Ltd. Vs. CIT, 306 ITR 182 (Del) Instalment Supply (P) Ltd vs CIT 149 ITR 52 (Del)– 6 I.T.A. No.3204/DEL/2015 CIT vs Ayesha Hospitals (P) Ltd: 292 ITR 266 (Mad) CIT vs Dr. A.M. Singhvi: 302 ITR 26 (Raj) Kanpur Dyeing & Printing Co vs CIT: 76 ITR 686 (All) Thiru Arooran Sugars Ltd. vs DCT: 350 ITR 324 (Mad) 6. Regarding non deduction of TDS, he submitted that, firstly, provision of Section 40(a)(ia) is not applicable in the present case, because major expenditure is towards purchase of material an…

GODFREY PHILIPS INDIA LTD,MUMBAI vs. ADDL CIT 8(1), MUMBAI

In the result, the ground raised by the assessee is allowed

ITA 5317/MUM/2015[2011-12]Status: DisposedITAT Mumbai13 Sept 2019AY 2011-12

Bench: Shri Rajesh Kumar & Shri Amarjit Singhassessment Year: 2011-12

For Appellant: Shri Yogesh Thar, A.RFor Respondent: Shri Choudhary Arun Kumar Singh, D.R
Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “G”, MUMBAI BEFORE SHRI RAJESH KUMAR, ACCOUNTANT MEMBER AND SHRI AMARJIT SINGH, JUDICIAL MEMBER Assessment Year: 2011-12 M/s. God Frey Philips Addl CIT 8(1), India Ltd., Aayakar Bhavan, Sahara Road, Vs. Mumbai Chakala Andheri (E), Mumbai – 400 049 PAN: AABCG 4768K (Appellant) (Respondent) Present for: Assessee by : Shri Yogesh Thar, A.R. Revenue by : Shri Choudhary Arun Kumar Singh, D.R. Date of Hearing : 18.07.2019 Date of Pronouncement : 13.09.2019 O R D E R Per Rajesh Kumar, Accountant Member: The present appeal has been preferred by the assessee against…

ITO 3(3)(3), MUMBAI vs. THEBROMA FOODS P.LTD, MUMBAI

In the result, the appeal of the Revenue in ITA no

ITA 765/MUM/2017[2012-13]Status: DisposedITAT Mumbai09 Apr 2019AY 2012-13

Bench: Shri Mahavir Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.765/Mum/2017 (नििाारण वर्ा / Assessment Year : 2012-13) बिाम/ Ito 3(3)(3) M/S. Theobroma Foods R.No. 672, Pvt. Ltd., Aayakar Bhavan, 101, Jamuna Sagar, V. M.K. Road, 59/60, Shahid Bhagat New Marine Lines, Singh Road, Mumbai-400020 Colaba, Mumbai 400005 स्थायी ऱेखा सं./ Pan: Aacct0588K (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. Revenue By: Shri. D.G Pansari (Dr) Assessee By: Shri. Rohan Deshpande सुनवाई की तारीख /Date Of Hearing : 28.01.2019 घोषणा की तारीख /Date Of Pronouncement : 09.04.2019 आदेश / O R D E R Per Ramit Kochar: This Appeal, Filed By Revenue, Being Ita No. 765/Mum/2017, Is Directed Against Appellate Order Dated 28.10.2016 In Appeal No. Cit(A)-8/It-344/15-16, Passed By Learned Commissioner Of Income Tax (Appeals)-8, Mumbai (Hereinafter Called ―The Cit(A)‖), For Assessment Year(Ay) 2012-13, The Appellate Proceedings Had Arisen Before Learned Cit(A) From The Assessment Order Dated 31.03.2015 Passed By Learned Assessing Officer (Hereinafter Called ―The Ao‖) U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Called ―The Act‖) For Ay 2012-13. I.T.A. No.765/Mum/2017

For Appellant: Shri. Rohan DeshpandeFor Respondent: Shri. D.G Pansari (DR)
Section 143(2)Section 143(3)Section 30

…• Cymroza Art Gallery V/s ACIT (2013) 21 ITR (Trib) 262 (Mum) • DCIT V/s Bijesh Thakkar (2012) 49 SOT 502 (Mum.) • Instalment Supply P.Ltd V/s CIT (1984) 149 ITR 52 (Del) • CIT V/s Dr.A.M.Singhvi (2008)302 ITR 26 (Raj) • CIT V/s Ayesha Hospitals P.Ltd (2007) 292 ITR 266 (Mad) • ACIT V/s M.M.Publications Ltd. (2011) 43 SOT 59 (Cochin) 5.2.7 In view of the above facts and circumstances, the net disallowance of Rs. 82,09,912/- (after depreciation) is deleted. This ground of appeal is allowed.‖ I.T.A. No.765/Mum/2017 6. The Revenue is aggrieved by the appellate order dated 28.10.2016 passed by Ld. CIT(A) and it w…

GEM HOSPITAL AND RESEARCH CENTRE PRIVATE LIMITED ,COIMBATORE vs. ACIT CORPORATE CIRCLE 2 , COIMBATORE

In the result, the appeal of the assessee is allowed

ITA 1620/CHNY/2017[2014-15]Status: DisposedITAT Chennai17 Dec 2018AY 2014-15

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.1620/Chny/2017 "नधा रण वष /Assessment Year:2014-15

For Appellant: Shri Hari Govind, JCIT

…existing building. In this regard, the assessee took us through the paper book and relied on the Jurisdictional High Court decisions in the case of Thiru Arooran Sugars Ltd. v. DCIT [2013] 31 taxmann.com 3 (Mad) and CIT v. Ayesha Hospitals (P.) Ltd. [2007] 292 ITR 266 (Mad). The ld. AR submitted that the ratio laid in the case of CIT v. Ayesha Hospitals (P.) Ltd. (supra) perfectly applies to this case. Per contra, the ld. DR supported the orders of lower authorities. 4. We heard the rival submissions and gone through the relevant materials. The undisputed facts are that the assessee has taken the buildings o…

B & A DIGI TACTICAL SOLUTIONS PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee stands dismissed

ITA 304/CHNY/2017[2013-14]Status: DisposedITAT Chennai28 Aug 2017AY 2013-14

Bench: Shri Abraham P. George]

For Appellant: Shri. B. Sagadevan, IRS, JCITFor Respondent: 23-08-2017
Section 31Section 32Section 37

…आयकर अपील"य अ"धकरण, ‘’ ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ (SMC) BENCH : CHENNAI "ी अ"ाहम पी. जॉज", लेखा सद"य के सम" । [BEFORE SHRI ABRAHAM P. GEORGE, ACCOUNTANT MEMBER] आयकर अपील सं./I.T.A. No.304/Mds/2017 "नधा"रण वष" /Assessment year : 2013-2014 B & A Digi Tactical Solutions Vs. The Deputy Commissioner of Pvt. Ltd, Income Tax, No.1, Lalithpuram Street, Corporate Circle 1(2) Royapettah, Chennai. Chennai 600 014. [PAN AAECB 3553G] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. N.V. Balaji, Advocate अपीलाथ" क" ओर से/ Appellant by : Shri. B. Sagadevan, IRS, JCIT. ""यथ" क" ओर से /Responde…

DCIT, CHENNAI vs. N.RAGHUNATH, CHENNAI

In the result, all the three appeals of the Revenue are dismissed

ITA 3224/CHNY/2016[2012-13]Status: DisposedITAT Chennai07 Jun 2017AY 2012-13

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

For Appellant: Mrs. Pavuna Sundari, JCITFor Respondent: Shri. T.N. Seetharaman, Advocate

…eal. Contra, the AR invited our attention to the CIT(A) order in :-5-: I.T.A. N0. 3223 & 3224/Mds/2016 ITA No. 235, 236 & 237/CIT(A)-2/2014-15 dated 30.09.2005, wherein the CIT(A) relying on the following decisions a) CIT Vs Ayesha Hospitals P. Ltd (2007) 292 ITR 266 (Mad) b) Thiru Arooran Sugars Ltd. Vs. DCIT (2013) 350 ITR 324 (Mad) c) CIT Vs Armour Consultants P. Ltd (2013) 355 ITR 418 (Mad) d) CIT Vs. Amrutanina Ltd. (2011) 15 Taxmann.com 392 (Mad) e) M/s. Sundaram BNP Paribas Asset Management Company Ltd. Vs. ACIT ITA No. 518 & 519/Mds/2010 f) M/s. Emdee Apparels Vs. ACIT (2012) 28 Taxmann.com 10…

DCIT, CHENNAI vs. N.RAGHUNATH, CHENNAI

In the result, all the three appeals of the Revenue are dismissed

ITA 3223/CHNY/2016[2011-12]Status: DisposedITAT Chennai07 Jun 2017AY 2011-12

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

For Appellant: Mrs. Pavuna Sundari, JCITFor Respondent: Shri. T.N. Seetharaman, Advocate

…eal. Contra, the AR invited our attention to the CIT(A) order in :-5-: I.T.A. N0. 3223 & 3224/Mds/2016 ITA No. 235, 236 & 237/CIT(A)-2/2014-15 dated 30.09.2005, wherein the CIT(A) relying on the following decisions a) CIT Vs Ayesha Hospitals P. Ltd (2007) 292 ITR 266 (Mad) b) Thiru Arooran Sugars Ltd. Vs. DCIT (2013) 350 ITR 324 (Mad) c) CIT Vs Armour Consultants P. Ltd (2013) 355 ITR 418 (Mad) d) CIT Vs. Amrutanina Ltd. (2011) 15 Taxmann.com 392 (Mad) e) M/s. Sundaram BNP Paribas Asset Management Company Ltd. Vs. ACIT ITA No. 518 & 519/Mds/2010 f) M/s. Emdee Apparels Vs. ACIT (2012) 28 Taxmann.com 10…

DCIT, CHENNAI vs. AMEC FOSTER WHEELER INDIA PRIVATE LIMITED, CHENNAI

In the result, appeal of the assessee in ITA

ITA 1762/CHNY/2016[2009-10]Status: DisposedITAT Chennai06 Jan 2017AY 2009-10

Bench: Shri Abraham P. George & Shri G. Pavan Kumar

For Appellant: Shri. Sriram Seshadri, C.A Department by : Shri. A.V. Sreekanth, IRS, JCITFor Respondent: Shri. A.V. Sreekanth, IRS, JCIT
Section 143(3)Section 147

…es 1,78,487 Total 2,57,98,076 As per the assessee, above expenditure did not result in creation of any new asset nor gave it any enduring benefit. Reliance was placed on the judgment of Jurisdictional High Court in the case of CIT vs Ayesha Hospitals P. Ltd 292 ITR 266 and Thiru Arooran sugars Ltd vs. DCIT, 350 ITR 324. However, ld. Commissioner of Income Tax (Appeals) was not impressed by the above contention. He held as under:- ‘’10. Renovation per se would be a composite item of activity which would be violated in its concept if the same is split up into smaller fragments. This is so as these smaller indivi…

AMEE FOSTER WHEELER INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, appeal of the assessee in ITA

ITA 1531/CHNY/2016[2009-10]Status: DisposedITAT Chennai06 Jan 2017AY 2009-10

Bench: Shri Abraham P. George & Shri G. Pavan Kumar

For Appellant: Shri. Sriram Seshadri, C.A Department by : Shri. A.V. Sreekanth, IRS, JCITFor Respondent: Shri. A.V. Sreekanth, IRS, JCIT
Section 143(3)Section 147

…es 1,78,487 Total 2,57,98,076 As per the assessee, above expenditure did not result in creation of any new asset nor gave it any enduring benefit. Reliance was placed on the judgment of Jurisdictional High Court in the case of CIT vs Ayesha Hospitals P. Ltd 292 ITR 266 and Thiru Arooran sugars Ltd vs. DCIT, 350 ITR 324. However, ld. Commissioner of Income Tax (Appeals) was not impressed by the above contention. He held as under:- ‘’10. Renovation per se would be a composite item of activity which would be violated in its concept if the same is split up into smaller fragments. This is so as these smaller indivi…

DCIT, CHENNAI vs. AMEC FOSTER WHEELER INDIA PRIVATE LIMITED, CHENNAI

The appeal of the assessee is partly allowed for statistical purposes whereas that of the Revenue is dismissed

ITA 1761/CHNY/2016[2008-09]Status: DisposedITAT Chennai25 Nov 2016AY 2008-09

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

For Appellant: Shri. Sriram Seshadri, C.AFor Respondent: Shri. A.V. Sreekanth, IRS, JCIT
Section 32(1)

…the assessee, above expenditure did not result in creation of any new asset nor gave it any enduring benefit. Reliance was placed on the judgment of Jurisdictional High Court in the case of CIT vs Ayesha ITA Nos.1530& 1761/Mds/2016 :- 4 -: Hospitals P. Ltd 292 ITR 266 and Thiru Arooran sugars Ltd vs. DCIT, 350 ITR 324. However, ld. Commissioner of Income Tax (Appeals) was not impressed by the above contention. He held as under:- ‘’10. Renovation per se would be a composite item of activity which would be violated in its concept if the same is split up into smaller fragments. This is so as these smaller indiv…

AMEE FOSTER WHEELER INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

The appeal of the assessee is partly allowed for statistical purposes whereas that of the Revenue is dismissed

ITA 1530/CHNY/2016[2008-09]Status: DisposedITAT Chennai25 Nov 2016AY 2008-09

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

For Appellant: Shri. Sriram Seshadri, C.AFor Respondent: Shri. A.V. Sreekanth, IRS, JCIT
Section 32(1)

…the assessee, above expenditure did not result in creation of any new asset nor gave it any enduring benefit. Reliance was placed on the judgment of Jurisdictional High Court in the case of CIT vs Ayesha ITA Nos.1530& 1761/Mds/2016 :- 4 -: Hospitals P. Ltd 292 ITR 266 and Thiru Arooran sugars Ltd vs. DCIT, 350 ITR 324. However, ld. Commissioner of Income Tax (Appeals) was not impressed by the above contention. He held as under:- ‘’10. Renovation per se would be a composite item of activity which would be violated in its concept if the same is split up into smaller fragments. This is so as these smaller indiv…

THE CONTINENTAL ENTERPRISE,CHENNAI vs. ITO, CHENNAI

In the result, the appeal of the assessee in ITA

ITA 700/CHNY/2014[2008-09]Status: DisposedITAT Chennai11 Sept 2015AY 2008-09

Bench: Shri N.R.S. Ganesan & Shri Chandra Poojari] आयकर अपील सं./I.T.A.No.700/Mds/2014 "नधा"रण वष" /Assessment Year : 2008-2009

For Appellant: Shri. S. Sridhar, AdvocateFor Respondent: Shri. P. Radhakrishnan, IRS, JCIT
Section 32

…आयकर अपील"य अ"धकरण, ‘ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘ A’ BENCH : CHENNAI "ी एन.आर.एस. गणेशन, "या"यक सद"य एवं "ी चं" पूजार", लेखा सद"य के सम" । [BEFORE SHRI N.R.S. GANESAN, JUDICIAL MEMBER AND SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER] आयकर अपील सं./I.T.A.No.700/Mds/2014 "नधा"रण वष" /Assessment year : 2008-2009 The Continental Enterprise The Income Tax Officer, 621, 1st floor, SIRE Mansion, Vs. Business Ward XV(2), Anna Salai, Chennai Chennai 600 006. [PAN AACFT 8487A ] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Shri. S. Sridhar, Advocate ""यथ" क" ओर से /R…

COMPUTER ACCESS PVT. LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA

ITA 3084/CHNY/2014[2005-06]Status: DisposedITAT Chennai02 Sept 2015AY 2005-06

Bench: Shri Chandra Poojari

For Appellant: Shri. A.S. Sriraman, AdvocateFor Respondent: Shri. A.B. Koli, IRS, JCIT
Section 32Section 32(1)

…0324 (Mad) wherein it was held that ‘’the Expenditure incurred in respect of maintenance of leased premises is deductible as revenue expenditure’’. Similar view was also taken by the jurisdictional High Court in the case of CIT vs. Ayesha Hospitals (P) Ltd 292 ITR 266, wherein it was held I.T.A.No.3084/Mds/2014 :- 7 -: that ‘’ Expenditure incurred by assessee on painting relaying of damaged floors, partitions etc. in leasehold premises is allowable as revenue expenditure’’. 6. Being so, taking a consistent view on the above matter, I am inclined to allow the appeal of the assessee. 7. In the result, the a…

SHERVANI HOSPITALITIES LTD. vs. COMMISSIONER OF INCOME TAX

The appeal is disposed of

ITA/804/2011HC Delhi28 May 2013
Section 143(3)Section 271(1)(c)

…ted as a revenue expense. The expenditure included polishing of floor, wooden paneling etc. Reference in this regard may also be made to decisions of the Madras High Court and the Punjab and Haryana High Court in CIT vs. Ayesh Hospitals Pvt. Ltd. 2007 292 ITR 266 (Mad.) and CIT vs. Porrits & Spencer (A) Ltd. (2002) 257 ITR 49 (P&H). 19. We have extensively referred to these judgments, only to show that the issue raised by the assessee was debatable and capable of two views. The assessee had an arguable case or had taken a bonafide plea. The assessee had given his explanation and categorically a…

COMMISSIONER OF INCOME TAX vs. EDS ELECTRONIC DATA SYSTEMS (INDIA ) PVT LTD

ITA - 474 / 2009HC Delhi04 Oct 2012
Section 10ASection 143(3)Section 234DSection 30Section 31Section 37(1)Section 80H

…he other hand by remitting the matter, in fact acted contrary to the enacted provisions. 7. Learned counsel for the assessee relied upon decisions reported as CIT v. Hi Line Pens Pvt. Ltd, (2008) 306 ITR 182 and CIT v. Ayesha Hospitals P. Ltd., (2007) 292 ITR 266 and contended that the expenditure incurred for the improvement of lease hold premises as in the present case was deductible under Section 37(1) of the Act; it was also submitted that if the Revenue’s request for remitting the matter for examination of the entire expenditure, including what was allowed by the AO himself, were to be acceded t…

COMMISSIONER OF INCOME TAX vs. (INDIA) PVT. LTD

ITA/474/2009HC Delhi04 Oct 2012
Section 10ASection 143(3)Section 234DSection 30Section 31Section 37(1)Section 80H

…he other hand by remitting the matter, in fact acted contrary to the enacted provisions. 7. Learned counsel for the assessee relied upon decisions reported as CIT v. Hi Line Pens Pvt. Ltd, (2008) 306 ITR 182 and CIT v. Ayesha Hospitals P. Ltd., (2007) 292 ITR 266 and contended that the expenditure incurred for the improvement of lease hold premises as in the present case was deductible under Section 37(1) of the Act; it was also submitted that if the Revenue’s request for remitting the matter for examination of the entire expenditure, including what was allowed by the AO himself, were to be acceded t…