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2018 (11) TMI 1884 - AT - Income TaxEstimation of assessee’s income @ 0.4% of its total turnover - CIT-DR vehemently contends during the course of hearing that CIT(A) has erred in law as well as on facts in estimating assessee’s income @ 0.4% of its total turnover - HELD THAT:- CIT-A fails to dispute the fact the CIT(A) has gone by his findings in earlier assessment years thereby adopting the judicial consistency. The said estimation in earlier assessment years has admittedly attained finality. There is no other material to dispute correctness thereof failed during the course of hearing. We therefore find no fault in CIT(A)’s action estimating the assessee’s income @ 0.4% of its turnover. Disallowance u/s. 40(a)(ia) - non-deduction of TDS - Revenue’s latter substantive ground seeking to revive u/s 40(a)(ia) (supra) that has no legs to stand since the relevant books forming foundation thereof already stand rejected. The Revenue fails in its both substantive grounds accordingly. Appeal of revenue dismissed.
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