TaxTMI 
TaxTMI 
2026 (9) TMI 847
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....nt : Sh.Tarun Sharda, Sr.DR. ORDER PER MANISH AGARWAL, A.M.: The present appeal is filed by assessee against the order dated 26.02.2026 passed by Ld. Commissioner of Income Tax (A)-27, New Delhi ["Ld. CIT(A)"] in Appeal No. CIT(A), Delhi-27/10091/2022-23 u/s 250 of the Income Tax Act, 1961 ["the Act"] arising out of assessment order dated 30.03.2025 passed u/s 143(3) of the Act pertaining....
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....e to these 03 parties of INR 1,60,83,564/- remained unverified. It is further observed by the AO that all the 03 contractors had not filed their ITRs therefore, genuineness of the transactions remained unproved. Accordingly, AO disallowed 30% of the total payment which comes to INR 48,25,069/- and the total loss was assessed at INR 13,51,98,542/-. 3. Aggrieved by the said order, the assessee fi....
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....e notices issue u/s 133(6), the payments made to them were doubted and adhoc disallowance was made. Ld.AR submits that when part expenses were accepted as genuineness and the services rendered by them were not doubted and were admitted and therefore, no disallowance be made. Ld.AR further submits that arbitrarily disallowance @ 30% without basis on assumptions and presumption deserves to be delete....
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....t is an admitted fact that notice issued u/s 133(6) of the Act remained non-complied. Further they have not filed their return of income for the year under appeal therefore, the expenditure incurred as paid to them remained unverified. Under these circumstances, before making any disallowance, the AO should have examined the services rendered by them. However, the AO has not doubted the services r....