2025 (4) TMI 1949

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....lowing grounds of appeal: Disallowance of labour charges u/s 40(a)(ia) of the Act of Rs. 2,50,234/-: 1. The Id. CIT(A) erred in upholding the addition of labour charges on account of non-deduction of TDS to the tune of Rs. 2,50,234/- (being 30% of 8,34,119/-) without appreciating that assessee had provided party-wise ledgers of labour charges and TDS deducted, therefore the disallowance sustained without providing the list of parties whose TDS was deductible but not deducted, the disallowance made under section 40(a)(ia) is not justified. II. Addition on Account of undisclosed rental income of Rs. 9,53,134: 2. The Ld. CIT(A) erred in upholding the addition on account of undisclosed rental income to the tu....

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....e revenue authorities. After evaluating the facts of the present case, we noticed that in the order of Ld. CIT(A) it is specifically been mentioned that assessee has claimed and debited Rs. 86,79,511/- towards labour charges and deducted TDS on an amount of Rs. 78,25,366/- and with regard to the difference, the assessee was silent even reconciliation in this regard was not furnished. 5. Be that as it may after hearing the parties at length we are of the view that the issue in question requires reconciliation and verification therefore without going into the merits of this issue, we are of the view that matter needs to be restored back to the file of the AO reconciliation and verification and thereafter for adjudicating afresh on merits. ....