2025 (6) TMI 1472

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The Revenue has filed separate applications seeking condonation of delay in filing of appeals. After perusing the applications for condonation of delay, I am satisfied that delay in filing of present appeals is un-intentional and was for the reasons stated in the applications which appear to be bonafide. Hence, delay of 5 days in filing of appeal for AY 2014-15 and 2015-16 is condoned and appeals are admitted for hearing on merits. 3. For the sake of convenience the facts are narrated from appeal of the Revenue for AY 2014-15. ITA No 4743/Del/2024 (AY 2014-15) 4. The Revenue in appeal has assailed the order of CIT(A) on the following ground:- "1. Whether ld. CIT(A) has erred in holding that no specific case has been made for either add....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....dings of the AO. The CIT(A) held that as regards genuineness of services rendered by the aforesaid parties, the AO has not pointed any inconsistency in the bills raised or question of the genuineness of nature of services provided by the parties. All the parties have accepted the transaction and have also offered to tax in their respective returns amount received from the assessee. The assessee has also deducted TDS on the payments. Against the aforesaid findings of the CIT(A), the Revenue is in appeal before the Tribunal. 6. Shri Ashish Tripathi, vehemently defended the assessment order and prayed for reversing findings of the CIT(A) on this issue. The ld. DR submits that the assessee has failed to prove genuineness of the expenditure, he....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

...., after examining the facts of the case held as under:- "5. During assessment proceedings the AO had issued notice u/s. 133(6) of the Act to these parties. In response to said notice, the said parties had filed confirmations and also stated that services were provided by them. The CIT(A) in the impugned order has recorded a finding of fact that the aforesaid parties had offered receipts from assessee to tax in their respective return of income, TDS was deducted by the assessee on the payments made to the parties. These facts have not been refuted by the Assessing Officer. Further, in response to the show cause notice dated 18.03.2024 the assessee had furnished reconciliation, no adverse findings have been given by the AO on the reconcilia....