Section 37 of Income Tax Act, 1961— In the instant case, Revenue in its appeal is impugning deletion of disallowance of Rs. 1,31,76,000/-. Certain administrative expenditure of Rs. 2,52,031/- were claimed out of which Rs. 2,16,574/- has been deleted by the ld.CIT(A).

Held that— The disallowance at Rs. 1,44,000/- per acre out of expenditure claimed at Rs. 4,44,000/- is almost more than 30% of the expenditure claimed by the assessee. To our mind, even if there are lacunae in maintaining details at the end of the assessee, and he has claimed some inflated expenditure, that should be around 8% to 10% of the total and not 30%, because in this activity maximum profit even for the contract could be estimated at 8%.

Therefore, in our opinion, ends of justice would meet if we scale down this disallowance of expenditure of Rs. 63,59,000/- to Rs. 30,00,000/-. We direct accordingly.[DCIT, CENT. CIR. 1 (2) AHMEDABAD. VERSUS SHRI NILESH TEJABHAI PATEL PROP. GROW MORE BRASS PRODUCTS][2019] 18 ITCD Online (18) [ITAT AHMEDABAD]