2016 (1) TMI 985

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...., these were heard together and are being disposed of by this consolidated order for the sake of convenience. ITA No. 1182/Ahd/2010 : AY 2006-07 2. In this appeal, the Revenue has raised following grounds of appeal:- 1) On the facts and circumstance of the case and in law, the Ld. CIT(A) has erred in deleting the rejection of book results u/s 145(3) of the Act and the addition of Rs. 25,01,995/- on account of low net profit. 2) On the facts and in the circumstances of the case, the Ld. CIT(A) ought to have upheld the order of the Assessing Officer. 3) It is, therefore, prayed that the order of the Ld.CIT(A) may be set aside and that of the Assessing Officer be restored to the above extent. 2.1 The brief f....

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.... the net profit of Rs. 1,86,779/- disclosed by the assessee, the Assessing Officer made the addition of Rs. 25,01,995 to the assessee's total income. 3. Matter was carried before the First Appellate Authority wherein various contentions were raised on behalf of the assessee and having considered the same, the CIT(A) has deleted the addition in question on both accounts. The same has been opposed before us on behalf of the Revenue inter alia submitting that the CIT(A) has erred in deleting the rejection of book result u/s 145(3) and the addition of Rs. 25,01,995/- on account of low net profit; accordingly, the Departmental Representative submitted that the order of the CIT(A) may be set aside and that of Assessing Officer be restored.....

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.... payment of Rs. 37,000/- as recorded in the ledger and Rs. 39,000/- as per the responding voucher, was too insignificant to be taken into account when compared to the total labour expenditure of Rs. 1,23,17,102/-. The other objection with regard to vouchers did not reflect whether the payments were made to skilled labourers or unskilled labourers, was also found of no significance by the CIT(A). Even though the rates would obviously have been different yet, it was not required for the vouchers to show whether paid to skilled or unskilled labour. It has to be seen whether payments are bogus or not. The Assessing Officer observed that the assessee had shown outstanding labour payment of Rs. 28,60,400/- but had failed to identify the sites for....