2025 (7) TMI 966

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....e assessee against the assessment order passed u/s. 144 of the Income-tax Act, 1961 [the Act] dated 23.12.2019 by the ITO, Ward 2(3), Mangalore [ the ld. AO ] was partly allowed. 2. The assessee is aggrieved and has preferred this appeal raising the following grounds:- "1. The order of the learned authorities below in so far as it is against the appellant is opposed to law, equity, facts, weight of evidence, probabilities and circumstances of the case. 2. The learned authorities below are not justified upholding disallowance of Cooly and Labour charges Rs, 34,60,350/-, and disallowance of Farm Expenses amounting to Rs. 3,81,124/- on the facts and circumstances of the case. 3. The Learned Authorities below erred in not allowing the Co....

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....aw on facts and circumstances of the case. 8. Without pre-judice to any other contention, the disallowances are highly excessive and deserve to be reduced substantially. 9. The appellant craves leave to add, alter, amend, substitute, change and delete any of the grounds of appeal. 10. For the above and other grounds that may be urged at the time of hearing of the appeal, the appellant prays that the appeals may be allowed and Justice rendered." 3. The assessee is basically aggrieved with the finding of the ld. CIT(A) in confirming the disallowance of coolie & labour charges of Rs. 34,60,350 and expenditure of Rs. 3,81,124 on account of farm expenses. 4. Briefly stated facts of the case show that assessee is a company engaged in the ....

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....e of this nature is common in this kind of business. With respect to farm expenditure, it was found to be primarily cost related to enhanced cultivation and maintenance of crops. The income from this farm was already included in the revenue of the assessee. When the vouchers were produced, the ld. AO held that these are self-made vouchers for purchase of manure and other labour expenses. The finding of the AO is that these expenses appears to be reasonable. However, the ld. CIT(A) confirmed both the above additions and assessee is in appeal. 6. We have heard Shri Ravishankar S.V., Advocate who relied upon the remand report of the AO and also heard the ld. DR. After careful consideration, we find that in the remand report with respect to th....