2024 (9) TMI 344

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....RDER PER B.R. BASKARAN, ACCOUNTANT MEMBER : The assessee has filed this appeal challenging the order dated 11/01/2024, passed by learned Addl/JCIT (A)-4, Chennai, and it relates to the assessment year 2021-22. The solitary issue urged in appeal relates to addition of Rs. 60,19,934/- made by CPC u/s. 41(1) of the Income Tax Act, 1961 [in short 'the Act'], while processing return of income u/s....

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.... Account. Since it is credited to the profit and loss account, the net profit disclosed by the assessee already included the above said amount. Consequently, the same has already been offered to tax by the assessee. However, while processing the return of income, the CPC added the above said amount again. It is the grievance of the assessee that the addition so made by the CPC has resulted in doub....

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....in double taxation of same item of income. 6. The Ld A.R submitted that the "Column 14, Part A-01" in the return of income is a case of abstract reporting of certain details. Hence the Ld CIT(A) was not justified in confirming the addition only on the reasoning that the assessee has reported the details in Column 14. She further submitted that the Tax Auditor has also reported the details of ab....

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....net profit disclosed in the profit and loss account and hence the total income has already included the above said income. Hence, there is no requirement of making addition of aforesaid amount u/s. 41(1) of the Act again. Hence the addition made by CPC has resulted in double taxation of same item of income, which is not permitted under the Act. Accordingly, the said addition is liable to be delete....