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The ITAT upheld the assessee's claim for expenses paid to contractors for loading and unloading, as supported by banking transactions and TDS deductions. Contractors confirmed providing labor, and cash withdrawals were for labor payment. The AO's claim of ex-employees as contractors was justified for reliable labor supply. The allegation of unexplained investment in land purchase was dismissed as the deal did not materialize. Sales-tax subsidy was deemed a capital receipt, requiring quantification by the AO. The matter of 14A provisions was remanded to the AO for further examination.
The ITAT upheld the assessee's claim for expenses paid to contractors for loading and unloading, as supported by banking transactions and TDS deductions. Contractors confirmed providing labor, and cash withdrawals were for labor payment. The AO's claim of ex-employees as contractors was justified for reliable labor supply. The allegation of unexplained investment in land purchase was dismissed as the deal did not materialize. Sales-tax subsidy was deemed a capital receipt, requiring quantification by the AO. The matter of 14A provisions was remanded to the AO for further examination.
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