2025 (4) TMI 1942

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....he Department : Shri Dayainder Singh Sidhu, CIT(DR) ORDER PER SHAMIM YAHYA, AM : Assessee has filed the Appeal against the order dated 01.5.2023 passed by the Ld. CIT(A)-Noida-3, relating to assessment year 2019-20. 2. Brief facts of the case are that in this case, return of income was filed on 30.10.2019 declaring total income of Rs. 22,67,310/-. Notice u/s. 143(2) of the Act was issu....

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.... inoperative for the part of the year. The handling charges reduced from Rs. 88 lacs in the preceding year to Rs. 55 lacs in the current year. From the profit and loss accounts of FY 2017-18 and 2018-19, it can be seen that HPCL COD handling charges in FY 2017-18 were Rs. 88,21,870/- and the same reduced to Rs. 55,78,819/- in FY 2018-19. Thus there is reduction of Rs. 32,44,051/-. Now this receipt....

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.... and loss accounts of FY 2017-18 and 2018-19, it can be seen that there is no such balance written off in FY 2017-18 and the same is Rs. 8,13,629/- in FY 2018-19." 2.1 Thereafter, Ld. CIT(A) granted part relief by observing as under:- "Therefore, from the records it has been found that the appellant has successfully explained some circumstances which were responsible in reduction of NP....

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.... Rs. 82,18,690/- is reduced by Rs. 45,85,996/- since the reduction in the profit to this extent has been found as explained. Therefore addition of Rs. 36,32,694/- [Rs. 82,18,690/- (-) Rs. 45,85,996/-] is hereby upheld. 3. Against the above order, assessee is in appeal before us. 4. We have heard both the parties and perused the records. Ld. Counsel for the assessee pleaded that though AO has....