2025 (4) TMI 1891

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....p firm engaged in the business of Civil Contractors and sale of bitumen under the name and style "M/s. R.R. Kapoor. Income of Rs. 5,12,459/- declared in the return for the A.Y. 2014- 15 furnished on 25.03.2015. After the case being selected for complete scrutiny through CASS and validly serving of notices u/s.143(2) and 142(1) of the Act, assessment proceedings were carried out and after considering the submissions of the assessee income assessed at Rs. 12,47,305/- after making few disallowances. Though the assessee challenged these additions before the ld. CIT(A) but failed to succeed. The assessee is now in appeal before me raising various four grounds of appeal. 3. Ground No.1 by the assessee reads as under : "1. On the basis....

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....as claimed as an expenditure in the profit and loss account. Ld. AO treated the said sum being the payment made towards offence for the activity prohibited by law and applied Explanation 1 to section 37 disallowing the said sum. I however on going through the record notice that the assessee turnover is approximately Rs. 19.00 crore. The assessee is in the regular course of business and applied for contract with PWD. It is evident that the assessee had refused to carry out the contract. The refusal can be for many reasons like lesser contract amount, difficulty in carrying out the awarded work in the prescribed time limit or lack of resources etc. This is purely the decision of the Management to carry out the business activity and they have ....