2026 (1) TMI 886

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....shok Goyal (CA) - Ld. ARs For the Respondent : Dr. Ranjit Kaur (Addl. CIT) - Sr. DR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2018- 19 arises out of an order of learned Commissioner of Income Tax (Appeals)-3, Gurgaon [CIT(A)] dated 29-01-2025 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 143(3) of t....

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....ed wherein the assessee opposed any such addition. In the light of recorded statements during survey, Ld. AO rejected the contentions of the assessee and proceeded to make the addition in the hands of the assessee. It was assumed by Ld. AO that similar expenditure would have been incurred by the assessee throughout the year and by extrapolating the figures as mentioned in this sheet, Ld. AO made a....

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....sessee is shown to have made payment of Rs. 2,54,115/- to these employees for the month of July, 2017. The same has also been admitted by the cashier and the HR manager in their respective statements as extracted by Ld. AO in the assessment order. However, there is no admission that similar payment was made for rest of the other months also. In our considered opinion, the survey addition has to be....