2025 (3) TMI 2080

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....T(A)"] u/s. 250 of the Income-Tax Act, 1961 [hereinafter referred to as "Act"] for the Assessment year [A.Y.] 2021-22, wherein the limited ground of appeal leads to sustenance of addition of Rs. 56,25,000/- paid by the assessee toward professional charges for software development. 2. Briefly the facts of the case are that the assessee filed its return of income on 16.02.2002, declaring total income of Rs. 25,60,150/-. The case of the assessee was selected for scrutiny through CASS to examine large payment made u/s. 194J to persons who have not filed return of income. Thereafter, notices u/s. 143(2) and 142(1) were issued and thereafter after issue of show-cause, an addition of Rs. 56,25,000/- was made by the AO. As per the AO the assesse....

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....at the assessee has furnished unsigned copy of the software agreement entered into with this persons during the course of appellate proceedings and the assessee was asked to furnish the signed copy of the said agreements, however, there was no compliance on the part of the assessee. The Ld. CIT(A) accordingly held that the assessee has not made the complete payment to said professionals during the financial year relevant to impugned assessment year and has also not submitted the signed copy of the agreements entered with them and therefore he was of the opinion that the appellant couldn't establish the genuineness of the said transactions and the disallowance made by the AO was confirmed. 4. Against the said findings and directions of th....