2022 (2) TMI 1191

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....ed the impugned order on the following grounds of appeal: "1. Because, the Ld. Commissioner of Income Tax (Appeals) erred in law as well as on facts while confirming the lump sum addition of Rs. 2,50,000/- made by the Ld. Assessing Officer. 2. Because, the Ld. CIT(Appeals) has erred in overlooking and summarily rejecting the detailed statements of facts submitted along with written submission of appeal and accepted the incorrect version of the learned Assessing Officer. 3. The appellant reserves the right to add, amend or alter any ground or grounds of appeal." 2. Briefly stated, the assessee who is engaged in the business of manufacturing of CI casting & Ingot Moulds had filed e-filed its return of income for A.Y 2012-13, declaring ....

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....d or lacked the requisite information which was required to determine the proper amount of wages and salary payment. Backed by his aforesaid observation, the Assessing Officer in order to cover up the suppression of profit by the assessee worked out an ad-hoc disallowance of Rs. 2.50 lac out of the aforesaid wages and salary expenses. 3. Being aggrieved, the assessee carried the matter in appeal before the CIT(Appeals), however, without any success. 4. The assessee being aggrieved with the order of the CIT(Appeals) has carried the matter in appeal before us. We have heard the Ld. Authorized Representative for both the parties, perused the orders of the authorities below as well as materials available on record. As observed by us hereinabo....

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....e said line of business. However, we find that the aforesaid claim of the assessee had been summarily rejected by the Assessing Officer, i.e., without placing on record any material which would negate the veracity of the same. We, thus, in terms of our aforesaid observation are unable to subscribe to the adverse inferences drawn by the Assessing Officer by drawing support from the comparative fall in the Gross profit/Net profit ratio of the assessee during the year under consideration. 5. As regards the observation of the Assessing Officer that the assessee had debited a heavy amount on account of wages and salary which cannot be factually verified as the vouchers in support thereof did not contain the requisite details, i.e. working hours....