Commissioner Of Income-Tax, Baroda vs Navsari Cotton & Silk Mills Ltd. on 23 March, 1981
6. Before us, Ld. Departmental Representative for the Revenue filed
written note dated 22-11-2017 stating that the AO was justified in
invoking the provisions of section 37(1) of the Act for making
disallowance on the ground of unreasonableness or excessiveness. For
this proposition, he relied on various decisions justifying the
disallowance is proper when the same are made for extra commercial
considerations. He also relied on certain decisions mentioned in the
judgment of Gujarat High Court in the case of CIT Vs. Navsari Cotton
and Silk Mills 135 ITR 546 (Guj.)