2021 (4) TMI 779

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....n and confirmed addition of Rs. 9,83,475/- on account of disallowed of job work charges. 2. That assessee craves the right to add or amend the grounds of the appeal during the hearing or before the date of appeal." 2. The hearing of the appeal was concluded through video conference in view of the prevailing situation of Covid-19 Pandemic. 3. Brief facts of the case are that the A.O. made disallowance out of job work charges amounting to Rs. 19,66,951/- which was paid by the assessee in cash on the ground that the supported documents are not filed by the assessee, therefore, the same could not be verified. 4. Being aggrieved by the order of the A.O., the assessee carried the matter before the ld. CIT(A), who after considering the facts ....

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....without any specific reason and purely on the basis of suspicion, assumptions. Appellant was engaged in the business of demarcation, survey of colonies and map making. There are lots of unskilled labour were required for doing/ completion of a particular assignment. It is undisputed matter between nature of business and requirement of unskilled labour. Ld AO was also rightly accepted the requirement of cash paid labour in his order dated 19-12-2016 page no 2, para no 5, line no 2:- "It is admitted that for carrying out the work, labour is required and for that payment would have been made". [Paper Book Annexure 16-18] During the impugned assessment proceedings books of accounts along with vouchers, ledger copies were produced before....

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.... Revenue that the assessee has 24 (sic 224) branches, 8 divisional office and a head office. c. The expenditure claimed by the assessee related to petty cash expenditure. d. When the Revenue had thought fit to allow 90% of the claim, there was no reason to reject the balance 10% attributing it to the possibility of having the shade of a personal expenditure. e. Except for this reasoning, we do not find any justification in the Revenue's contention that the disallowance of 10% is warranted in the facts of the case. f. The order of Tribunal, being a pure factual issue the court rejected the appeal at the admission stage itself and in the result, the Tax Case (Appeal) was dismissed." [Paper Book Annexure 25-27] It is further su....

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....00 2. Car Insurance 56861.00 3. Cartage 118062.00 4. General Exp. 5975.00 5. Interest on car loan 20404.00 6. Interest on loan 145800.00 7. Job work paid 33265591.00 8. Petrol 71090.00 9. Printing & Stationary 143691.00 10. Refreshment Exp. 2298.00 11. Repair & Maintenance Expenses 282554.00 12. Staff Welfare 35000.00 13 Tour Travels 1950.00 14. Water 1298.00 15. Total 34152784.00 All those expenses were examined by the A.O. and it was found that the assessee paid job work charges of Rs. 3,32,65,591/-, out of this, amount of Rs. 19,66,951/- was paid in cash. Since complete supporting evidence for verification of expenses were not produced and only ledger account was furnished by the assessee which ....