2021 (2) TMI 957

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....rofessional Expenses paid on estimated basis @ 5% of the total payments amounting to Rs. 60,53,727/- and confirmation of the same by the CIT(A) is contrary to facts and law and therefore, the disallowance is liable to be deleted. 2. Disallowance of expenses paid to contractors @ 1% of the total payments amounting to Rs. 55,03,286/- and confirmation of the same by the CIT(A) is contrary to facts and law and therefore, the disallowance is liable to be deleted. 3. The appellant craves leave to add or amend any of the grounds of appeal." (B) The first ground of appeal pertains to disallowance amounting to Rs. 60,53,727/- out of professional expenses totaling Rs. 12,10,74,547/-. This disallowance @ 5% of total claim, was mad....

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.... concerned that the addresses of all the persons to whom contractual payments were made could not be submitted. (D) The non-compliances on the part of the assessee during proceedings before the AO and before Ld. CIT(A); as mentioned in foregoing paragraphs (B) and (C) of this order, which resulted in adverse view against the assessee by the authorities below are not in dispute. At the time of hearing before us, learned Authorised Representative ("Ld. AR", for short) of the assessee admitted that the non-compliances noted by the AO and by Ld. CIT(A) in their respective orders; were factually correct; in respect of both the aforesaid disallowances of Rs. 60,53,727/- and Rs. 55,03,286/-. He explained that the non-compliances by the assessee....