2026 (3) TMI 386

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....ct, 1961 (hereinafter referred to as 'the Act') passed by Assessment Unit,for AY: 2023-24. 2. Heard and perused the records. The assessee filed his return of income dated 31.10.2023 declaring income of Rs. NIL. The return was further revised for the year under consideration on 16.12.2023 declaring a total income of Rs. 10,62,91,110/-. Accordingly, the case was selected for scrutiny through CASS for verification of the issue and statutory notice under section 143(2) was issued on 19.06.2024. 3. During the relevant assessment year, the assessee was providing various assistances, advisory and commercial information services to Canpotex International Pte Ltd. to sell the Canadian Muriate of Potash (fertiliser). An exclusive market service....

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....dictory to the cash system. 8. Aggrieved by the assessment order the assessee filed an appeal before the CIT (A) and NFAC upheld the actions of the AO and dismissed the appeal of the assessee. Thus the assessee is in appeal and has raised following grounds; "1. That on the facts and circumstances of the case and in law, the appellate order passed by NFAC CIT(A) is contrary to the facts and bad in law. 2. That on the facts and circumstances of the case NFAC CIT(A) has erred in disallowing salary expenses amounting to Rs. 31,29,560/- by treating them as bogus business expenses as the appellant was not running any business with Canpotex international Pvt. Ltd. for the year under consideration. 2.1 That NFAC CIT(A)....

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....that the AO failed to consider this and made the additions without any application of mind. 9.1 It is submitted that even after the expiry the assessee tried to earn more business from the above mentioned however the deal did not fructify. It is submitted that during the assessment proceedings and appellant proceedings the assessee time and again explained that there has been a steep decline in the expenses of the business. It is submitted that during the relevant assessment year there has only been Rs. 41,72,750/- claimed as total salary expense compared to previous. It is submitted that the AO failed to consider comparatives drawn from previous years and confirmed the addition as personal expense. Relevant table has been filed on page ....