2021 (8) TMI 459

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....r 2017-18 is directed against the order of Ld. CIT(A)-9, New Delhi dated 31.07.2020. The assessee has raised following grounds of appeal:- 1. "Because on the facts and circumstances of the case and as per law, the learned Assessing Officer as well as the learned CIT(A) has failed to appreciate the business model of the appellant that it is only a manpower supplier through different organisations....

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..../s. 143(1) of the Income Tax Act, 1961 ("the Act"). Centralized Processing Centre ("CPC") while processing the return, disallowed the expenditure of the assessee at Rs. 31,71,449/- claimed in respect of employee's contribution. 3. Aggrieved against this, the assessee preferred appeal before Ld. CIT(A) who after considering the submissions, dismissed the appeal by observing as under:- 5.3. "....

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.... this appeal is against the disallowance of expenditure claimed on account of the employee's contribution to ESI & EPF. 6. Ld. Counsel for the assessee submitted that due to Corona pandemic, the evidences could not be filed before Ld. CIT(A). He submitted that during the previous year under consideration, the assessee had 1475 number of manpower which were deputed to the client(s) and it rece....