2022 (8) TMI 854

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.... be engaged in the business of constructing, operating and maintaining of toll roads for adequate connectivity to Vishakapatnam Port Trust. Assessee electronically filed its return of income for A.Y. 2016-17 on 11.10.2016 declaring loss of Rs.6,35,42,251/-. The case was selected for scrutiny and, thereafter, assessment was framed u/s 143(3) of the Act vide order dated 21.12.2018 and the total loss was determined at Rs.6,33,08,451/-. 4. Aggrieved by the order of AO, assessee carried the matter before CIT(A) who vide order dated 20.05.2019 in Appeal No.10450/18-19 dismissed the appeal of the assessee. Aggrieved by the order of CIT(A), assessee is now in appeal and has raised the following grounds: "1. That the Ld. CIT(A) failed to....

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....ssment proceedings. 5. That any other or further ground of appeal may be allowed to be taken at the time of hearing of appeal, which may be deemed necessary in the facts and circumstances of the case. 6. That the appellant be allowed to filed additional evidence, if so, required for proper prosecution of the case, based on the facts and circumstances, which has not been or cannot be educed or filed before lower authorities either because proper and sufficient opportunity was not provided or because it was not solicited or its need was not appropriated." 5. Before us, at the outset, Ld. AR submitted that though the assessee has raised various grounds but the sole controversy is with respect to making of addition of Rs.2,....

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....at M/s. T. R. Chadha & Co. are the internal auditors of the company and they are paid Rs.99,000/- as internal audit fees per annum. She submitted that in the books of accounts, assessee had made provision towards audit fees payable for the period 01.04.2015 to 31.03.2016 but M/s. T. R. Chadha & Co. has raised the bill in Financial Year 2016-17 as the assignment of internal audit was completed in F.Y. 2016-17 and therefore, they had not reflected the amount of internal audit fees in their books of accounts in F.Y. 2015-16. She further submitted that the confirmation of Rs. 99,000/- given by T. R. Chadda & Co. on 04.07.2015, which is noted by the AO in the order, was with respect to the internal audit fees paid to them for A.Y. 2015-16. She f....

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....ly she has not stated that she has not an employee of the assessee and she being a technical person could not submit the reply as expected by the authorities. She further submitted that the payments have been made to her in subsequent year as is evident from the details furnished in paper book. She further submitted that aforesaid payments are not in doubt and therefore there is no reason in making its additions. 10. Learned DR on the other hand supported the order of lower authorities. 11. We have heard the rival submissions and perused the material available on record. The issue in the present ground is with respect to the additions namely addition of Rs.99,000/- and Rs.1,34,880/-. With respect to the payment of Rs.99,000/-, it is t....