2025 (5) TMI 515

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....cer [AO] u/s. 147 of the Act on 31-03-2023. The grounds taken by the revenue are as under: - 1. The order of the learned Commissioner of Income Tax (Appeals) is erroneous on facts of the case and in law. 2. The Ld. CIT(A) erred in appreciating the fact that during the assessment proceedings, the Assessing officer made thorough verification about the existence of both M/s. Gayathri Infrastructure and Developers & M/s. Venkateshwara Developers and ascertained that both the entities were found to be non-existing. 3. The Ld. CIT(A) erred in recognizing the fact that despite having huge receipts viz Rs. 1,79,82,560/- paid to M/s. Gayathri Infrastructure and Developers & Rs. 1,38,50,560/- paid to M/s. Venukateshwara Dev....

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....Lacs as paid to these entities. 3. During first appeal, the assessee, inter-alia, contended that the payments were made to these entities in the course of purchase of land as they were power of attorney holders of the land owners. Further, the payments were through banking channel and proper KYC documents were obtained before making these payments. Therefore, no such reduction could have been made by Ld. AO. 4. The Ld. CIT(A), after perusal of sale deeds, rendered factual findings that the payments to the two entities was made as Power of Attorney holders of the sellers. These payments were appearing in the respective sale deeds as tabulated in para 6.3.1 of the impugned order. The impugned payments to the sellers as well as to both t....