TaxTMI 
TaxTMI 
2025 (7) TMI 125
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.... facts of the case are that assessee is a company engaged in the manufacturing of remote, setup boxes, battery etc. The return of income was filed on 29.09.2018 decaling total income of Rs. 4,14,490/-. A search and seizure operation was carried out u/s 132 of the Act at various business of the residential premises pertaining to Laxmi Remote Group of cases at Delhi NCR. A survey was also conducted at the business premises of the assessee u/s 133A constituted at B-28, Ground Floor, Savan Park, New Delhi on 23.08.2017. 3. During the course of search incriminating documents pertaining to assessee company found and seized, thus, the proceedings u/s 153C were initiated in the case of the assessee in terms of satisfaction note recorded on 02.09....
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....d. CIT(A) has grossly erred in upholding the addition of Rs. 2,02,239/- in respect of alleged shortage of stock without appreciating the facts and circumstances of the case. 3. That the Ld. CIT(A) has grossly erred both in law and on facts in sustaining the disallowance of Rs. 2,28,000/- out of the total sum of Rs. 6,00,000/-debited as salary in the profit and loss account. 4. The assessee craves to leave add, alter, and modify any other ground of appeal at the time of hearing." 4. With respect to the grounds of appeal No.1 & 2, Ld. AR submits that the stock was quantified and valued by the Departmental Officials during survey wherein various scrap items available were also included in the total quantity and value of th....
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....ich it is claimed by the assessee that there was excess stock of Rs. 11,04,629/- for which the additions confirmed by ld. CIT(A). He thus stated that now there remained no basis for the assessee to further claim for deductions out of the excess stock, he thus, requested for the confirmation of the order of Ld. CIT(A) which according to ld. DR is quite reasonable. 6. Heard both the parties it is seen that the total stock found was quantified, inventoried and valued by the survey authorities in presence of employees of the assessee who assisted in identifying and intimating the cost price, according to which total stock value was Rs. 92,30,654/-. Assessee during the course of appellate proceedings, it reworked the value of stock after taki....
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.... the parties, we find no error in the order of the ld. CIT(A). Accordingly, Ground No.2 of the assessee is dismissed. 8. In ground of appeal No.3, the assessee has challenged the disallowance of salary of Rs. 2,28,000/-. Before us, the Ld. AR submit that the salary out of total salary of Rs. 6,00,000/-, a sum of Rs. 3,00,000/- was claimed as paid to staff Rs. 2,40,000/- was paid as labour charges and the remaining amount of Rs. 60,000/- was paid towards accountancy charges. He further submits that the AO has allowed only 1,80,000/- for salary towards the Ms. Shilpa Behal, one of the staff member and further allowed Rs. 1,92,000/- paid to other four staff persons including labour and disallowed the remaining salary by ignoring the fact th....