Refund claim dismissed as time-barred under s.142(5); non-obstante clause read restrictively, merits not decided, self-assessment payments not mere de...
Assessee's project-completion revenue recognition upheld; income addition deleted under Guidance Note/AS-9 and percentage-completion rules as complian...
ITAT dismissed the Revenue's appeal and upheld in toto the order of the CIT(A) deleting the addition of Rs. 15.80 crore towards alleged bogus wage expenditure for A.Y. 2022-23 in the case of Assessee Co. ITAT held that the AO's reliance on cash scroll notings such as "MD Personal" was unsupported by any corroborative evidence, cash trail, or proof of personal use by the Managing Director, and that such private notings cannot, by themselves, constitute conclusive evidence of non-genuine expenditure. As the AO had not rejected the books under s.145, and the assessee's profit ratio was consistent with past years, the impugned disallowance was found arbitrary and unsustainable. All grounds raised by the Revenue were rejected.
ITAT dismissed the Revenue's appeal and upheld in toto the order of the CIT(A) deleting the addition of Rs. 15.80 crore towards alleged bogus wage expenditure for A.Y. 2022-23 in the case of Assessee Co. ITAT held that the AO's reliance on cash scroll notings such as "MD Personal" was unsupported by any corroborative evidence, cash trail, or proof of personal use by the Managing Director, and that such private notings cannot, by themselves, constitute conclusive evidence of non-genuine expenditure. As the AO had not rejected the books under s.145, and the assessee's profit ratio was consistent with past years, the impugned disallowance was found arbitrary and unsustainable. All grounds raised by the Revenue were rejected.
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