2025 (8) TMI 682

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....with Section 144B of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') for Assessment Year 2020-21. "1. That on the facts and circumstances of the case and in law, the final assessment order passed by the Ld. AO/ DRP is erroneous, contrary to the facts, based on surmises, conjectures and against the principles of natural justice and accordingly, the same is liable to be quashed. 2. That on the facts and circumstances of the case and in law, the Ld. AO has acted out of its jurisdiction while issuing the draft assessment order dated 25 September 2023 passed under Section 144C(1) of the Act as well as final assessment order since the said power lies only with the National Faceless Assessment Centre as per the pr....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....INR 7,40,715), 234B of the Act (amounting to INR 1,30,73,330) and increasing the interest under Section 234C (amounting to INR 7,49,340) of the That the above grounds are independent and without prejudice to each other. The appellant craves to add, amend, alter, delete, rescind, forgo or withdraw any of the above grounds of objection either before or during the course of the hearing." 2. 1st Ground is general in nature no order needs to be passed. 3. 2nd ground is not pressed by the assessee. Thus, the same is dismissed as not pressed. 4. 3rd Ground is consequential one, no order needs to be passed. 5. 4th Ground is general in nature, no order needs to be passed. 6. So far as the 5th ground is concerned in r....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....@ 12% per annum from the said date until such time the amount is actually deposited with the Welfare Commissioner." 8. The Ld. AR has further referred the payment details made by the employer appearing at page 7 of the compilation wherefrom it reflects that the payment was made on 30.01.2021 for the contribution period from 01.01.2020 to 31.12.2020. The said document further establishes the fact of assessee being governed by the Punjab Labour Welfare Fund Act, 1965. He has further referred the details of contribution received from the employees for various funds as per Section 36(1)(va) appearing at page 7 of the compilation, serial Nos. 22, 23 & 24 whereof speak of "any other welfare fund; due date for making payment is also reflecting ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....s Processing Outsourcing (BPO) services, including finance and accounting, collections, insurance, customer fulfillment, data modeling and analytics support, managed IT services, software solutions and elearning. The assessee had filed its return of income and which was later revised on 30.03.2020 declaring net income of Rs. 862,08,58,410/- under the normal provisions of the Act and book profit of Rs. 520,01,23,566/- u/s 115JB of the Act. The assessee during the year under consideration received sum towards employees' contribution to Labour Welfare Fund amounting to Rs. 15,16,090/-. The same were duly remitted to the account of the Govt within the due date specified under the respective labour law and duly disclosed in the tax audit rep....