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of <h1>Tax Tribunal Rejects Revenue's Appeal; Emphasizes Need for Concrete Evidence Over Estimates in Tax Assessments.</h1> <h3>Dy. Commissioner of Income Tax, Central Circle, Ghaziabad. Versus Rishabh Buildcon Pvt. Ltd.</h3> Dy. Commissioner of Income Tax, Central Circle, Ghaziabad. Versus Rishabh Buildcon Pvt. Ltd. - TMI Issues involved: Appeal against CIT(A) order deleting addition made by AO regarding contract receipts.Summary:Issue 1: Addition of Rs. 2,37,21,344/- by AOThe appeal by the Revenue was against the CIT(A)'s order dated 16.08.2021 for A.Y. 2011-12, where the Revenue contended that the CIT(A) erred in deleting the addition of Rs. 2,37,21,344/-. The AO found that the assessee had shown contract receipts of Rs. 2,93,44,779/- and other income of Rs. 23,61,809/-. Information received from Addl. CIT, Hyderabad, indicated suspicious transactions involving Totem Infrastructure Ltd. The AO made the addition based on estimated profit at 8% due to discrepancies in contract details and commission payments. However, the Tribunal found the addition to be speculative without concrete evidence, questioning the basis for estimating profit at 8%. Consequently, the appeal of the Revenue was dismissed as the addition lacked demonstrative evidence.This judgment highlights the importance of concrete evidence in making additions during assessment proceedings, emphasizing the need for a factual basis rather than speculation or conjecture.
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