2021 (3) TMI 650

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....s M/s. Raasi Associates, Hyderabad. It filed its return of income for the A.Y 2013-14 on 29.09.2013 admitting total income of Rs. 2,55,89,610/-. There was a survey operation u/s 133A on 24.1.2013 and during the course of survey, the Managing Partner of the assessee firm appeared and in his recorded statement, he agreed to offer the profit @Rs. 400 to 500/- per sq.ft. However, while filing the return of income for the relevant, A.Y, the assessee did not offer any additional income. Therefore, the difference of the undisclosed profit of Rs. 2,14,30,388/- was brought to tax. The AO observed that as per the declaration given by the assessee's Managing Partner, the profit of the firm should be at Rs. 4,70,20,000/- as against the profit declared ....

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....us year Le. for the assessment year 2012-13 was Rs. 500j- per sq. ft and the profit declared for the assessment year 2013-14 is also pertaining to the same project. 7. Any other ground(s) that may be urged at the time of hearing". 4. The learned DR supported the orders of the AO and submitted that the Managing Partner of the assessee firm himself has offered to admit additional income during the course of survey but did not offer the same in the return of income and the difference has rightly been brought to tax and the CIT (A), without proper verification has granted relief to the assessee. 5. The learned Counsel for the assessee, on the other hand, supported the orders of the CIT (A) and submitted that the statement of the Managing Pa....

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.... of survey no incriminating material establishing tax evasion was found iii. No material was found indicating that the profit earned by the appellant was at Rs. 500 per sq. ft. iv. The AO did not dispute the receipts or expenditure of the appellant v. There is no evidence with the department to indicate the profit at 500 Rs. per sq. ft. vi. The books of accounts bills vouchers as required by the AO were produced during the course of assessment proceedings and deficiency was pointed out. The above submissions and contentions of the appellant are a matter of fact and can be seen that these facts flow from the assessment orders. The appellant has further stated that a statement made by the appellant can be an indicative evidence and ....