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2022 (4) TMI 282 - ITAT CUTTACKRevision u/s 263 by CIT - ad hoc disallowance of expenses claimed - HELD THAT:- We clearly observe that the AO has not rejected books of account of the assessee but has made disallowance of 10% of claim of expenses on account of failure of the assessee to produce details of bills and vouchers in support of such claim of expenses made in the profit and loss account. Therefore, the contention that no further addition can be made on the basis same account, being devoid of merits, is dismissed. So far as non-consideration of reply to notice u/s. 263 on careful and vigilant reading of order dated 30.3.2014 u/s. 263 of the Act, we are of the considered view that the CIT has given thoughtful consideration to the submission of the assessee and also noted that the Ld. A.R. has not given any specific explanation with respect to issues raised in the show cause letter issued for initiation of proceedings u/s. 263. In view of this, the legal contention of the assessee as placed in Ground cannot be held as allowable and the same are also dismissed being devoid of merits. We find it just and proper to direct the AO to consider the contention, Explanation and relevant documentary evidences during reassessment proceedings in pursuance to order u/s. 263 by the AO and also during first appellate proceedings by the CIT(A). The CIT(DR) did not object to the prayer of the assessee for giving above direction to the AO.
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