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2023 (11) TMI 436 - AT - Income TaxSuppression of professional receipts from the patients under OPD category - assessee has shown some “Zero Receipt Patients” in IPD” indoor patient department - AO worked out average consultancy fees of OPD category @ Rs. 150/- per patient and added sum as unaccounted income of assessee - CIT(A) while passing order u/s 154 restricted such addition to the extent of 30% being profit element of unrecorded receipt and deleted remaining addition. HELD THAT:- We find that Assessing Officer has adopted a figure of Rs. 100/- as minimum charge and Rs. 3,00/- as maximum charge of consultancy fees in OPD and worked out average consultancy fees of Rs. 150/- per patient adopting average consultancy fees, is nothing but on presumption. We further find that assessing officer made similar addition in respect of indoor patient (IPD patient), and on appeal before ld CIT(A) it was also restricted to 30% by ld CIT(A) in order dated And on further appeal before Tribunal such additions were deleted [2022 (12) TMI 1472 - ITAT SURAT] - Decided in favour of assessee.
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