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2017 (12) TMI 615

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....nd Commissioning Charges" ignoring the fact that the assessee has failed before the A.O to specify the reason of less profit this year although turnover went up substantially as compare to last year. 2. That the order of the Ld.CIT(A) be set aside and that of the Assessing Officer be restored. 3. The assessee filed income tax return on 28/9/2011 at a total income of Rs. 1,81,18,370/-. The case of the assessee was selected for scrutiny and statutory notice u/s 143(2) of the Income Tax Act was issued on 26/9/2012 and was duly served on the assessee. The authorized representative of the assessee appeared from time to time and filed detailed reply along with books of accounts cash book ledger and other documents. The same was placed on reco....

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....as added to the total income of the assessee. 4. Aggrieved by the assessment order, the assessee preferred appeal before the CIT(A). The CIT(A) held that the Assessing Officer made estimated disallowances because of some expenses which had gone up, however, the Assessing Officer had not brought on record a single instance of expenses not being vouched properly, any instance of any of these expense being artificially inflated or being of a bogus nature. The CIT(A) further held that there was no allegation that the expenditure occurred out of any other activity and Assessing Officer did not bring on record any instance of the expenditure being used for purposes of the other business. Thus, the addition made in routine manner and on an ad-hoc....

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....not specified in any cogent manner why the explanation cited by the assessee for the increase in expenditures i.e. the fact that in the current year the most of the project work were done in different location of India which resulted in the increase, were not acceptable. He has not brought any instance on record that any of these expenditures were inadmissible to be deducted and he has also not explained why a particular percentage of the expenditure merits disallowance. Thus it appears that the addition has simply been made on a suspicion of leakage. No suspicion can be the basis of a sustainable addition. In the absence of any specific reference to any expenditure that the AO had found to not be incurred or to be incurred for a purpose ot....