2024 (2) TMI 689

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.... the Ld. CIT(A) grossly erred in law as well as on merits in estimating the net profit @8% and consequentially in upholding addition of Rs. 25,62,738/-. 1.2 That Ld CIT(A) has erred in law and facts in not considering the income already declared by the assessee. 1.3 That without prejudice, the net profit if any should not be more than 2.18% being average net profit for last 3 years. 1.4 That no proper and reasonable opportunity of hearing has been allowed. 2.1 That under the facts and circumstances of the case, the Ld. CIT(A) grossly erred in law in upholding addition of Rs. 33,25,689/- for disallowance u/s. 43B. 2.2 That no addition u/s. 43B should have been made once the profit is estimated and....

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....,83,14,508.00 2,86,63,967.00 3,60,92,346.00 PBT 1,35,607.00 6,63,870.00 62,23,722.00 Tax expenses 1,27,045.00 7,35,089.00 20,74,944.00 NP 2,62,652.00 -71,219.00 41,48,778.00 NP Ratio 0.82 0.21 5.94 6. The ld. AR placed reliance on following judicial pronouncements: * L.P.R. Construction Vs. DCIT, Circle-1 2021 (7) TMI 796 - ITAT ALLAHABAD. * Om Prakash Singh Vs. ACIT, Circle-3, Mathura 2019 (8) TMI 830 - ITAT AGRA. * CIT, Patiala Vs. M/s Hind Agro Industries 2015 (12) TMI 1407 - ITAT CHANDIGARH 7. On the other hand, the ld. DR submitted that the assessee has not produced any details of the expenses and the provisions of Section 145(1) of the Income Tax Ac....