2025 (3) TMI 1809

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....R. For the Revenue Represented : Shri Ravindra, Sr. D.R. ORDER PER : DR. BRR KUMAR, VICE PRESIDENT: Delay Condoned This appeal has been filed by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as "CIT(A)" for short) dated 26.04.2023 passed under Section 250 of the Income-tax Act, 1....

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....(ii) disallowance of Rs. 20,88,230/- being 10% of the total labour charges debited in profit & loss account of the assessee. 4. Aggrieved by the aforesaid additions made by the Assessing Officer, the assessee filed appeal before the ld. CIT(A) who deleted the addition of Rs. 4,55,435/-, but confirmed the addition of Rs. 20,88,220/- being disallowance of 10% of labour charges of Rs. 2,08,82,197/....

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....ies below. 8. Rebutting the stands of the Revenue, the Ld. AR submitted that, in order to end up the protracted litigation, the disallowance @ 6% would be agreeable provided that the same cannot be treated as a precedent for reopening of the case for the earlier years or for determination of the profit for the subsequent years. 9. Heard both the parties and perused the material available on ....