2021 (10) TMI 725

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....ance of Rs. 1,81,50,000/- u/s 37 (1) of the Income Tax Act, 1961 (the Act) on account of 'job charges' by ignoring the fact that the assessee failed to discharge its onus u/s 37 (1) of the Act to prove that the expenses were incurred wholly and exclusively for the purpose of its business? 2. Whether on facts and in circumstances of the case, the Ld. CIT(A) is legally justified in deleting the disallowance of Rs. 1,81,50,000/- u/s 37 (1) of the Act on account of 'job charges' without recording material evidence of giving such relief? 3. Whether on facts and in circumstances of the case, the Ld. CIT (A) is legally justified in deleting the disallowance of Rs. 1,81,50,000/- u/s 37 (1) of the Act on account of &#39....

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....amounting to Rs. 24.60 crores on account of wage/salary and job charges and also to justify the increase in expenses as compared to last year. 3.2 In response, the assessee furnished the reply on 22.03.2016 whereby enclosed ledger account of wages, salary and job charges. The AR in the said reply stated that the turnover of the company during the FY 12-13 has been increased to INR 6.74 crores as against the last F.Y 11-12 Rs. 36.53 crores. To execute more orders during company has incurred high labour cost in comparison to previous financial year ... 3.3 During the course of assessment proceedings, the vide note sheet entry dated the AR of the assessee was asked why increase of Rs. 18.15 crores in job work charges, 10% of ....