2023 (7) TMI 31

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....') in ITA No. 675/SRT/2018 for AY 2013-14. 2. Heard learned standing counsel Mr. Nikunt Raval appearing for the appellant - department. 3. Factual matrix of the present case is as under: 3.1. The respondent - assessee company has filed its return of income for AY 2013-14 on 28.9.2013 declaring total income of Rs. 57,45,077/-. The case of the respondent assessee was selected for scrutiny. Thereafter, assessment u/S. 143(3) of the Act was completed on 28.3.2016 assessing the total income of the assessee at Rs. 4,32,54,749/- by making addition of Rs. 3,74,27,513/- on account of difference in payment received as per Section 26AS and as per books and Rs. 82,159/- on account of disallowance of payment of employees contribution towards PF after....

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....eedings, the assessee has claimed that there was double deduction of TDS on the same project which was entered into with the two different parties at the time of bill raised and also at the time of payment made on certain bills. 6. Learned counsel referred the order passed by the AO and pointed out that the AO has correctly made additions of Rs. 3,74,27,513/- on account of difference in payment received as per Section 26AS. 7. At this stage, learned counsel has referred the observations made by the tribunal while dismissing the appeal filed by the appellant herein and contended that the tribunal has not properly appreciated the fact that AO has rightly made additions of the aforesaid amount while passing the assessment order. 8. Learned ....