TaxTMI 
TaxTMI 
2015 (2) TMI 1427
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....onfirming the Assessing Officer's action to add Rs. 9,66,194/- by applying provision of section 145(3). It is respectfully submitted that appellant has tried to reconcile the said difference with the information received u/s.133(6). However, due to shortage of time and lack of details available, appellant could not reconcile the same at the time of hearing. 2. The Learned Commissioner of Income-tax (Appeals) - 26, Mumbai ["Ld. CIT (A)"] erred in confirming the Assessing Officer's action to add Rs. 5,35,000/- on account of Commission paid. It is respectfully submitted that the said addition is made on the basis of assumptions and without any concrete evidence on record. 3. The Learned Commissioner of Income....
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.... sites as per the orders received from its principal M/s. Perq Advertising (P) Ltd. In fact the sites are identified and procured on the basis of needs of various clients of its principal M/s. PAPL. During the course of assessment proceedings the AO noted that the work of the assessee is only purchase of site and selling the same to M/s. PAPL. Thus, the AO was of the view that the various expenses claimed by the assessee on account of conveyance, telephone, sundry vehicle expenses, office transportation, sales promotion, commission etc. are purely personal in nature and has no connection with the business. To verify the allowability of expenses and relation with the business activity of the assessee, the AO sought information u/s. 133(6) of....
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....ising due to issuance of Notice u/s. 133(6) of the Income tax Act, 1961 and the same will be added to the total income of the assessee after applying the provisions of section 145(3) of the Income tax Act, 1961. Initiate penalty proceedings u/s. 271(1)(c) of the Income tax Act, 1961 on this point for furnishing accurate particulars and concealment of income." 3.1 Despite invoking provisions of section 145(3) the AO proceeded to disallow various other expenses and computed total income of the assessee as under :- Computation of Total Income: Amount in Rupees Income as per Returned Income 1789076 Add: Additions as discussed in this order (i) Addition on account of in....