2026 (1) TMI 1318

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....rd-2(1)(2), Agra (hereinafter referred to as 'ld. AO'). 2. The only effective issue to be decided in this appeal is as to whether the ld AO could be stated to have validly assumed jurisdiction u/s 147 of the Act and whether the ld CITA was justified in confirming the disallowance of expenditure on ad hoc basis in the facts and circumstances of the instant case. 3. I have heard the rival submissions and perused the materials available on record. The assessee is engaged in the business of construction and had filed its return of income for AY 2016-17 on 17.09.2016 declaring income of Rs.3,48,150/-. The case of the assessee was sought to be reopened u/s 147 of the Act based on the information posted on Insight Portal that the assessee ha....

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....count of under reporting of consideration in gross receipts on account of sale of land. For the purpose of this issue, the Assessing Officer duly accepted the audited books of account furnished before him and concluded that entries recorded therein are correct warranting no addition on account of under reporting of gross receipts as mentioned in the reasons recorded for reopening the assessment. For the purpose of disallowance of expenditure incurred towards bricks and labour payments, the ld Assessing Officer concluded that books of accounts were not maintained by the assessee properly and proceeded to make 10% ad hoc disallowance and completed the reassessment. Hence, it is very clear that no addition has been made by the ld Assessing Off....