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2018 (12) TMI 1503 - AT - Income TaxDisallowing assessee’s salary expense as bogus - CIT DR vehemently contends seeking to revive the impugned salary disallowance as bogus expenditure - Held that:- We make it clear first of all that assessee has already filed a compilation chart of its total salary and wages vis-a-vis service income right from assessment year 2009-10 to impugned assessment year 2011-12 sufficiently indicating the impugned expenditure to be within same range. It has come on record that assessee runs 24 working establishments at different places and its payees ESI/PF details form part of record. AO never made even a single effort to either summon any of the assessee’s payees or for getting their records verified from State Insurance or PF authorities. We therefore conclude that the CIT(A) has rightly reversed assessment findings disallowing assessee’s salary expenditure claimed to be bogus in this peculiar facts and circumstances. The Revenue fails in its instant first substantive ground therefore. Addition in the nature of undisclosed income due to alleged difference shown and Form 26AS - Held that:- Assessee has successfully reconciled the impugned difference emanating for the sole reason of non-recognition of income in the impugned assessment year. The Revenue fails to dispute all these clinching reconciliation details. - Decided against revenue
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