Virtuous Finance Ltd , Mumbai vs Assessee
Similar is the view of the jurisdictional High Court in the case of
Central Bank of India (supra). Admittedly the CIT(Appeals) has not made
a disallowance based on actual expenditure. The disallowance was made
based on allocation of proportionate expenditure. This, in our considered
view, cannot be upheld as it is against the proposition laid down by the
jurisdictional High Court.