2025 (3) TMI 1972

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....hary, Addl.CIT, Ld. DR ORDER PER GAGAN GOYAL, A.M: This appeal by assessee is directed against the order of NFAC, Delhi dated 23.10.2024 passed u/s. 250 of the Income Tax Act, 1961 (in short 'the Act'). The assessee has raised the following grounds of appeal: - 1. The Ld. CIT(A), NFAC has erred on facts and in law in dismissing the appeal filed by the assessee holding that since ....

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....amongst the non-filers of the return u/s. 139 of the Act. In the case of the assessee information as per ITS details, the assessee received receipts u/s. 194A and 194H of the Act to the tune of Rs. 28,83,556/- from M/s. Rajasthan State Beverages Corp. Limited (RSBCL) and M/s. PACL India Limited during the year under consideration. In view of this a notice u/s. 148 of the Act was issued vide dated:....

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....uor purchase by M/s. RSBCL and as the facts even before the AO and Ld. CIT(A) are self-explanatory that the assessee was retail liquor vendor, the whole number of receipts can't be the taxable figure. Rather the profit embedded therein only can be taxed. 4. In the light of above facts, being a retail trader of liquor section 44AD is squarely applicable to the assessee and a profit margin @ 8% o....

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....ent facts are available on record before us and to avoid another round of hearing and wastage of public time and money, we deem it fit to adjudicate the matter, taking into consideration the Ground No.2 raised by the assessee. 5. The facts that the assessee under consideration is a retail liquor vendor is not under challenge. In view of this, we don't hesitate in holding that the provisions of ....