2025 (8) TMI 357

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....Ld. Addl./JCIT(Appeals)-1, Coimbatore dated 07.12.2023 for the AY 2003-04 in sustaining the ad hoc addition of Rs. 1,35,040/-. 2. Brief facts are that the assessment of the assessee for AY 2003-04 was reopened u/s 147 of the Act by issue of notice u/s 148 of the Act. In the course of assessment proceedings though several notices were issued to Assessee there was no compliance by the assessee. The....

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....r the assessee submitted that the Assessing Officer in the course of assessment proceedings issued summons to the company and obtained Form 16 issued by M/s Raunaq Automotive Components Ltd. for the AY 2003-04 which is placed at page 17 of the Paper Book. As per this Form 16 the assessee received salary of Rs. 3,74,560/- only. However, the Assessing Officer while completing the assessment presumed....

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....ich was obtained in the course of assessment proceedings from the company namely M/s Raunaq Automotive Components Ltd. in which the assessee was a Director. The Ld. Counsel, therefore, submits that the income of the assessee should strictly be considered as per Form 16 issued by the company. 5. The DR, on the other hand, placed reliance on the orders of the authorities below. 6. Heard rival subm....

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..../- when compared to the income declared by the assessee for the AY 2000-01. 7. In my considered view both the authorities below failed to consider the income of the assessee as per Form 16 issued by the company for AY 2003-04 which clearly shows that the assessee was paid an amount of Rs. 3,74,560/-. There is no evidence brought on record by the Assessing Officer that the assessee had earned sala....