TaxTMI 
TaxTMI 
2026 (7) TMI 863
X X X X Extracts X X X X
X X X X Extracts X X X X
....ax Act, 1961 for the A.Y. 2017-18 on 27.12.2019. The grounds of appeal are as under:- "1. The Learned CIT(A) erred in confirming the disallowance made by the Assessing officer (learned AO') with respect to bonus paid to employees of Rs. 85,40,130 under section 36(1)(ii) of the Act considering the same to be in the nature of profits or dividend. 1.1. The Learned CIT(A) erred in not considering and appreciating the additional evidence submitted under Rule 46A of the Income-tax Rules, 1962 (Rules) wherein the appellant had a letter from the tax auditor confirming that there was a typographical mistake in the tax audit report filed. 1.2. The Learned CIT(A) erred in not appreciating the fact that the mistake in rep....
X X X X Extracts X X X X
X X X X Extracts X X X X
....he audit report dated 3.10.2017 in which it was stated that bonus that had been paid to the employees was otherwise payable by him as profits or dividends as per section 36(1)(ii). Therefore, since the audit report itself stated that the bonus would otherwise be payable as profits or dividends, the ld. AO disallowed the same and added it to the income of the assessee. Furthermore, the ld. AO enquired into the reduction in income and increase in refund as a result of the revised return and was informed that the reduction in income and the increase in the refund was due to interest income being considered twice in the original return. However, the ld. AO noted that the income in the income tax return was derived from the audited financial sta....
X X X X Extracts X X X X
X X X X Extracts X X X X
....he books of accounts was Rs. 85,40,130/- which had been paid before the due date for furnishing of return of income under section 139(1) and the same had been reported in para 26(1)(B)(a) of 3CD report but the same had also been mistakenly typed under para 20(a) of 3CD inadvertently and had nothing to do with the actual transactions. However, the ld. CIT(A) pointed out that no steps had been taken to rectify the audit report or to file revised audit report and therefore, he held that the story was an attempt to cover up and accordingly he dismissed these grounds of the assessee. 4. With regard to the issue of addition of Rs. 2,05,01,909/- on account of disallowance on claim of additional deduction, the assessee had submitted that the int....
X X X X Extracts X X X X
X X X X Extracts X X X X
....y the filing of a revised tax audit report as the provisions for revision of Audit Report under Sub Rule 3 of Rule 6G of Income Tax Rules, 1962 only came into effect from 1st April, 2021 i.e. from A.Y. 2021-22. It was submitted that without any evidence to suggest that the clarification was anything but genuine, the ld. CIT(A) was not justified in refusing to consider it so. With regard to the addition made by the ld. AO towards interest income amounting to Rs. Rs. 2,05,01,909/-, it was submitted that the circumstances that led to double reporting of interest income had been explained to the ld. CIT(A), in that, since Utkarsh Coreinvest Limited had earned the interest prior to transfer of its micro finance business and had declared the same....