2025 (9) TMI 564

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....e of order 23/02/2024. The impugned order was emanated from the order of the National e-Assessment Centre, Delhi (NEAC) (for brevity the "Ld. AO") passed under section 143(3) read with section 144B of the Act, date of order 22/04/2021. 2. The assessee has taken the following groundsof Appeal:- "The following grounds of appeal are independent and without prejudice to each other. The appellant objects to the order dated 22 April 2021 passed under section 143 r.w.s. 1448 of the Income-tax Act (the Act) by the National Faceless Assessment Centre, Delhi (Ld. AO) for the aforesaid assessment year on the following among other grounds: Ground 1-Assessment Order is bad in law The Assessing Officer (hereinafter referred to as ....

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....shed inaccurate particulars of income and hence directed to initiate penalty proceedings u/s 270A. The Appellant craves leave to add, alter, amend, substitute or withdraw all or any of the Grounds of Appeal herein and to submit such statements, documents and papers as may be considered necessary either at or before the appeal hearing so as to enable the Hon'ble Tribunal members to decide these according to the law." 3. We heard the rival submissions and considered the documents available in the record. The Ld.AR stated that the ground No.1 of the assessee is not pressed. Hence, ground 1 of the assessee is dismissed as not pressed. 4. The assessee is engaged in the business of providing air tickets and working as agent of ....

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....ction" amount to Rs. 4,32,37,204/-. In reply, the assessee filed the submission, but the Ld.AO disallowed the said expenses and added back with the total income of the assessee. The aggrieved assesse filed an appeal before the Ld. CIT(A). The Ld.CIT(A) has considered all the written submissions of the assessee, but finally appeal of the assessee was dismissed. 5. The Ld.DR argued and fully relied on the order of the revenue authorities. 6. In our considered view, the assessee had claimed the expenses in prior years as provisions for doubtful debts. These expenses pertain to the assessee's business activities and are linked to the loss of funds invested during the ticket booking process in earlier years. We note that the expenses in qu....