TMI Blog2022 (3) TMI 1125X X X X Extracts X X X X X X X X Extracts X X X X ..... d. AR has stated at the Bar that the assessee is in position to reconcile the difference and in fact, there are no differences in the contract receipts which have been offered in the return of income as contractually accrued to him and receipts as per Form 26AS which the assessee can demonstrate through his books of accounts and supporting documentation once an opportunity is provided to the assessee. Taking into consideration the undertaking so given by the Ld. AR and with the understanding that the assessee shall cooperate and shall not abuse the opportunity so provided, the matter is set aside to the file of the AO to verify the differences after providing reasonable opportunity of hearing to the assessee. The assessee is also direct ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , who is proprietor of M/s. Vijay Good Carrier, has filed his return of income declaring taxable income of ₹ 7,05,630/-, which was selected for scrutiny through CASS to verify whether contract receipts/fees have been correctly offered to tax. Subsequently, notices u/ss 143(2) and 142(1) of the Act were issued to furnish details regarding contract receipts u/ss 194C and 194J of the Act, as per Form 26AS alongwith documentary evidence. In response, no reply was filed by the assessee. Thereafter, from the perusal of the return of income filed by the assessee, the AO observed that the assessee has shown gross receipts from contract business amounting to ₹ 80,99,254/-, whereas gross receipts from contract business as per Form No. 26A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ry evidence to reconcile the difference in entries. Even in the counter-comments to the remand report filed, the appellant has first tried to evade the issue by saying that the difference was not in his control due to them being added by the third party in the 26 AS Form. In my opinion, this is just an excuse to evade the issue and no concession can be granted on that. Hence, I confirm the addition made. The grounds of appeal are dismissed. 4. During the course of hearing, the Ld. AR submitted that only real income in the hands of the assessee can be brought to tax and though the assessee couldn't submit the reconciliation as sought before the lower authorities, all the documents and ledger accounts are on record and the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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