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ITAT upheld the CIT(A)'s deletions and allowed the appeal in favour of the assessee. The Tribunal held that disallowance of director's salary was unjustified: the director was a foreign national duly qualified, had rendered services, and had declared remuneration in her return, so the AO's addition was dismissed. Regarding rejection of books, ITAT found the AO had rejected accounts and made summary additions solely on observed declines in gross and net profit ratios without issuing specific queries, obtaining explanations, or recording cogent reasons or defects in maintenance of books; accordingly the assessments based on such summary rejections were set aside and the Revenue's grounds were dismissed.
ITAT upheld the CIT(A)'s deletions and allowed the appeal in favour of the assessee. The Tribunal held that disallowance of director's salary was unjustified: the director was a foreign national duly qualified, had rendered services, and had declared remuneration in her return, so the AO's addition was dismissed. Regarding rejection of books, ITAT found the AO had rejected accounts and made summary additions solely on observed declines in gross and net profit ratios without issuing specific queries, obtaining explanations, or recording cogent reasons or defects in maintenance of books; accordingly the assessments based on such summary rejections were set aside and the Revenue's grounds were dismissed.
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