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2019 (2) TMI 1344 - AT - Income TaxReversing assessment u/s 263 - addition on account of difference in 26AS statement regarding receipts realized from the assessee’s seven payer parties - additions of amount on which TDS has been deducted - HELD THAT:- Assessee is engaged in travel agent and tour operation business. The only issue herein is that of re-conciliation of the corresponding statements in from 26AS vis-a-vis assessee’s computation of income declared pertaining to the impugned assessment year. The CIT(A) has examined assessee’s all seven parties’ ledgers, details and receipt in issue to come to the conclusion that it had rightly not treated gross sum of its receipts as income as per Form 26AS statement. The assessee mainly derives commission income only from the parties/payers concerned after maintaining ledgers of its customers whose payments are made in advance. As rightly not treated all the receipt amounts as its income as confirmed by the corresponding ledger accounts. We make it clear that these clinching ledger accounts of its parties have gone unrebutted during the course of assessment as well as the instant second appeal proceedings before us. We conclude in these facts that the CIT(A) has rightly deleted the impugned addition made by the Assessing Officer alleging lack of reconciliation between assessee’s total receipts vis-a-vis the income component admitted therein in its computation. - Decided against revenue
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