2022 (11) TMI 1249

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....s Ltd) ("the assessee") for the assessment year 2007-08, assessee preferred this appeal. 2. Brief facts of the case are that the assessee is in the business of acquiring land and developing the land for plotting and subsequent sale. For the assessment year 2007-08 the assessee filed the return of income on 7/11/2007 declaring a loss of Rs. 5,45,187/- and by order dated 30/12/2009 section 143(3) of the Income Tax Act, 1961 (for short "the Act") the income of the assessee was determined at Rs. 5,20,100/-. Assessee filed appeal against this order. When matters stood thus, Ld. CIT-VI, Hyderabad passed an order under section 263 of the Act directing the learned Assessing Officer to redo the assessment, holding the assessment order to be preju....

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....ince it is natural in the business of the assessee to make such payments, the same cannot be doubted. So also the case in respect of the payment of Rs. 35.75 lakhs. 6. Per contra, Ld. DR submitted that inasmuch as there is no evidence whatsoever in support of the claim of the assessee, the authorities below have no option but to disallow such claim and therefore, there are no grounds to interfere with such considered findings. 7. We have gone through the record in the light of the submissions made on either side. Insofar as this addition of Rs. 80,46,778/- is concerned, learned Assessing Officer reduced the land development expenses to the extent of Rs. 80,46,778/- on the ground that the payment to the extent of Rs. 54,50,525/- to two....