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2020 (9) TMI 315 - AT - Income TaxDisallowance of sub-contract payments for land development expenses - accommodation entries for income and expenditure both - AO completed the assessment u/s. 144 and the amount of land development expenses was added to the total income of the assessee - HELD THAT:- CIT(A) is unjustified in treating the entire contract receipt as a taxable income of the assessee without disproving the material fact that assessee was indulged in facilitating accommodation entries. Assessee has not carried out any development work for the PACL Ltd. and provided accommodation entries to PACL Ltd. and on similar basis accommodation entries were provided by the subcontractor to the assessee. The assessee has failed to furnish the description of the land and other details where the land development work was carried out and the sub-contractors have also admitted in their statements and the affidavits they have only provided accommodation entries. Assessee have not executed any work except providing accommodation entries, we consider that looking to the meager income shown by the assessee it will be reasonable to estimate the commission income earned by the assessee @ 4% of ₹ 1,02,04,082/- to the amount of ₹ 4,08,165/-. - Decided partly in favour of assessee.
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