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2021 (2) TMI 269 - AT - Income TaxAd-hoc disallowance @ 7.5% on trading expenses - failure to submit the documents - HELD THAT:- CIT(A)/AO decided the case of the assessee on the basis of the material available on record and have not considered the past or subsequent year history of the profit earned by the assessee. Before us the assessee had shown the reasonable cause for non submission of documents before the Commissioner as well as before the assessing officer. Taking into account the facts and circumstances of the matter and in the interest of substantial justice, we concur with this plea of assessee for sending back the matter to the file of CIT(A). As it is highly unlikely that the assessee would intentionally or deliberately not produce the documents before the revenue authorities, as this would cause immense harm to his own interests. Ultimate aim of the assessment by the revenue authorities is to collect correct taxes due from the assessee We set aside the order passed by the Commissioner and remand the matter to CIT (A) - Appeal of the assessee is allowed for statistical purposes.
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