2023 (3) TMI 856

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....sed by the Ld. CIT (A) is arbitrary, unjustified and bad in law. 2. The Ld. CIT(A) erred in law and on facts in not deleting the addition of Rs. 576731/- being alleged difference in contract receipts as compared with Form 26AS. That the CIT (A) ignored the apparent factual position that the contractees had wrongly declared TDS details in their TDS returns. 3. That the Ld. C[T(A) erred in law and on facts in setting aside to AO the matter of addition of Rs.576731/- in the name of verification of appellant's claim with Form 26AS while the AO had admittedly made the addition solely on the basis of same Form 26AS. 4. On the facts and in the circumstances of the case, the Ld. AO erred in making and the Ld. CIT (A) erred in confirming t....

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....rnover as per Difference (Rs.) Form 26AS Books 1 CityCom Networks Private Limited 70,477/- 0 70,447/- 2 Haryana City Gas Distributors Ltd. 20,28,755/- 15,22,501/- 5,06,254/- Total 5,76,731/- 5. Upon assessee's appeal, ld. CIT (A) gave part relief with following directions :- "4.3.4 The appellant has further mentioned that the Assessing Officer at no point of time during assessment proceedings ever asked the appellant for any such justification or proposed to make any addition with respect to alleged difference in turnover pertaining to the aforesaid two parties. Considering this and as 26AS of the respective years are available with the Assessing Officer, Assessing Officer is directed to verify the claim of the appellant w....