2018 (3) TMI 80

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....as taken the following grounds of appeal :- "On the facts and in the circumstances of the case, the ld. CIT(A) has erred in - (i) Deleting the addition of Rs. 13,10,807/- on account of disallowance of expenditure u/s 40A(3) of the IT Act, 1961. (ii) Deleting the addition of Rs. 6,46,62,207/- (Rs.4,18,25,817/- + Rs. 1,87,80,500/-) on account of disallowance of expenditure as per provisions of section 40a(ia) of the IT Act, 1961." 3. Briefly stated, the facts, as culled out from record, are that the assessment was completed u/s 143(3) of the Act on 28.10.2010 determining the income at Rs. 2,44,16,267/- . Thereafter the learned Assessing Officer after being satisfied about the escapement of income to the tune of R....

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....als), remand report was called on both the issues relating to disallowance u/s 40A(3) of the Act at Rs. 13,10,807/- and u/s 40a(ia) of the Act at Rs. 6,46,62,207/- and the following comments were given by the Assessing Officer which are duly incorporated in the findings of the Commissioner of Income Tax (Appeals) :- Regarding disallowance u/s 40A(3) "8.3 The submissions of the appellant, the remand report of the A.O. which is reproduced above and the rejoinder of the appellant are considered. With respect to ground of appeal no. 4, the A.O. in his remand report in regard to the addition made under the head of Boulders & Murram Expenses has stated :- " The assessee has also stated that as per the copy of ledger of ....