2022 (2) TMI 107

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....DR ORDER Per S.S. Godara, JM 1. These two assessee's appeals for AYs. 2011-12 & 2012-13 arise from the PCIT-Hyderabad-4's separate orders dated 26-03-2021 & 23-03-2021 passed in DIN & Order No. ITBA/REV/F/REV5/2020-21/1031782779(1) & 1031685969(1), involving proceedings u/s. 263 of the Income Tax Act, 1961 [in short, 'the Act']; respectively. Heard both the parties. Case files ....

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.... on 14-12-2015 leading to initiation of Section 153A proceedings vide notice(s) dt. 26-12-2016. The Assessing Officer thereafter framed his impugned twin assessments on 26-04-2015 accepting the income(s) returned at the assessee's behest. It is in this backdrop of facts that the learned PCIT holds in his Section 263 revision orders in issue that on account of the assessee having not deducted T....

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.... behest is that of sub-contract payments only which in any case stands covered in the foregoing estimation of income being on debit side of the turnover. Same reasoning applies qua assessee's audit fee payment without non-deduction of TDS as well. We quote hon'ble jurisdictional high court's decision in Indwell Constructions Vs. CIT [232 ITR 776] (AP) that such disallowances/additions ....