2025 (2) TMI 1692

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....stava, SR.DR For the Respondent : Sh. Pankaj Gargh, adv. ORDER PER BENCH: This revenue's appeal for assessment year 2014-15 arises against Commissioner of Income Tax (Appeals)-2 [in short, the "CIT(A)"] Agra order dated 28.12.2018, involving proceedings under Section 143(3) of the Income Tax Act, 1961, [hereinafter referred to as 'the Act']. Heard both the parties. Case filed peruse....

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....to be restored. 4. That the appellant craves leave to add or alter any or more ground or grounds of appeal as may be deemed fit at the time of hearing of appeal." 3. Both the parties refer to the CIT(A)'s detailed discussion reversing the assessment findings rejecting the assessee's books thereby estimating its Net Profit @ 10% as under : "6.2 As regards the grounds no. 1(a), ....

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....2.3 (a) to 2.3(h) of its written submission and also examining the supporting evidences annexed by it in its written submission, I am convinced that the discrepancies identified by the A.O. in its books of account are either non-existent or are not supported by sufficient evidence. Further, with due respect to it, the A.O.'s reliance on the judgment in the case of M/s Hycons Infrastru....

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....to A.Y. 2012-13, the net profit has declined in the impugned year but is still greater than the net profit of A. Y. 2013-14, when it was a net loss of 26.73%. Finally, I find the judicial precedents cited by the appellant strongly support its contentions and cannot be brushed aside on the basis of facts available on record. Hence, in view of the above discussion grounds no. 1(a), 1(b), 2(....