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2020 (9) TMI 244 - HC - Income TaxEstimation of income @ 25% - advances received from its customers - Reopening of assessment u/s 147 - ITAT deleted the addition - whether assessee has worked as a contractor only and therefore revised provisions of AS-7 would apply for estimation of matching income on proportionate completion method? - HELD THAT:- We take notice of the fact that the AO in the assessment order has not discussed anything or rather has not been able to justify in any manner the addition of ₹ 3,38,44,000/- to the total income being 25% of the total receipts of ₹ 13,53,76,000/- as the business profit of the assessee for the year. No reason worth the name has been assigned by the AO in this regard. This exactly weighed with the CIT (A) while partly allowing the appeal of the assessee. The Tribunal ultimately concurred with the findings recorded by the CIT(A) and dismissed the appeal preferred by the Revenue. We are at one with the Tribunal in taking the view that the AO wrongly determined the profit at the rate of 25%, without any basis or credible material. No questions of law as proposed by the Revenue
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