2025 (9) TMI 1016

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....f Rs. 36,52,242/- made by the Assessing officer. 2. Briefly the facts of the case are that the assessment in this case was completed u/s. 147 r.w.s. 144 of the Income Tax Act, 1961 ("the Act") vide order dt.30-03-2022, wherein the AO brought to tax a sum of Rs. 36,52,242/- being 8% of the turnover of the assessee amounting to Rs. 4,56,53,030/-, which on appeal, has been sustained by the Ld.CIT(A) and against the said finding, the assessee is in appeal before us. 3. During the course of hearing, the Ld.AR submitted that the assessee-company has submitted during the course of assessment proceedings that it has received labour charges amounting to Rs. 4,56,53,030/- and it has worked out its income at Rs. 27,39,182/- being 6% of the total....

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....ingly submitted that the net profit may be estimated @ 6% of the gross receipts and necessary relief be provided to the assessee. 4. It was further submitted that the AO has not granted credit of full TDS as reflected in Form 26AS. In this connection, our reference was drawn to Form 26AS, which is placed as a part of assessee's Paper Book and it was submitted that as evident from the Form 26AS, there is a total TDS deducted on the payments to the assessee to the tune of Rs. 9,13,061/- and as against that, the AO has only given credit to the tune of Rs. 3,93,480/-. It was submitted that where the AO is accepting the gross receipts as per Form 26AS amounting to Rs. 4,56,53,030/-, there is no basis to dispute the corresponding TDS claim whi....