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TMI Blog2019 (10) TMI 661X X X X Extracts X X X X X X X X Extracts X X X X ..... TA No.2184/PUN/2013 : 2. This appeal is time-barred by 404 days. The assessee has filed an affidavit explaining the reasons which led to the late filing of the appeal. We are satisfied with such reasons. The delay is condoned and the appeal is admitted for hearing on merits. 3. The first issue raised in this appeal is against the enhancement made by the ld. CIT(A) to the tune of Rs. 124.53 lakh. 4. The assessee is running a manufacturing unit of wheel rims for two & three wheelers and auto components etc. A return was filed declaring loss of Rs. 4.06 crore odd. The assessment was finalised at a total loss of Rs. 3.26 crore. The assessee challenged the assessment order before the ld. CIT(A), who enhanced the income by Rs. 124.53 lakh. 5. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2007-08 and 2008-09. The assessee disputed such bills and did not record such amounts in the respective accounts. It was only on 22-12-2007 that an Agreement was arrived at between the assessee and Kinetic Engineering Ltd. reducing the bill amount from a total of Rs. 254.06 lakh to Rs. 211.59 lakh for both the years. The assessee claimed deduction of Rs. 211.59 lakh in its books of account for the year under consideration. The ld. CIT(A) accepted the grant of deduction of Rs. 87.06 lakh pertaining to the assessment year under consideration. He, however, held that the amount of Rs. 124.53 lakh pertaining to the immediately preceding assessment year could not be allowed as deduction against the income for the year under consideration and co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... deduction. We, therefore, overturn the impugned order and delete the enhancement of Rs. 124.53 lakh made by the ld. CIT(A) by treating it as prior period expenditure. 8. The second ground raised in this appeal is against the confirmation of disallowance to Rs. 17,49,623/-, being, 50% of disallowance made by the AO on account of non-genuine labour expenses. 9. The factual panorama of this ground is that the assessee showed payment of Rs. 18,49,824/- and Rs. 16,47,422/- to its two related concerns, namely, Sumesh Industries and Sushant Industries on account of job work charges. The AO recorded that the assessee could not evidence the movement of job from its concerns to the associated concerns. He, therefore, invoked the provisions of sect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng as to how the same was so. In the given circumstances, we are satisfied that no addition is called for. We, therefore, order to delete the addition. Mr. Sunil Munot - ITA No.1131/PUN/2014 : 11. This appeal is time-barred by 631 days. The ld. AR explained the reasons for delay with the assistance of an affidavit from the assessee. We are satisfied with the reasons so given. Accordingly, the delay is condoned and the appeal is admitted for disposal on merits. 12. The only issue raised in this appeal is against the enhancement by the ld. CIT(A) to the tune of Rs. 21.77 lakh. 13. Both the sides are in agreement that the facts and circumstances of this ground are mutatis mutandis similar to those of Ground No.1 in the case of Klassic Whee ..... X X X X Extracts X X X X X X X X Extracts X X X X
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