TMI Blog2020 (2) TMI 1174X X X X Extracts X X X X X X X X Extracts X X X X ..... e the genuineness of the transaction, more so, when the AO of the creditor also did not raise any doubt over it. Considering the above facts, order to delete the addition. Ad-hoc disallowance towards Salary to labourers - AO found certain infirmities in the details furnished in as much as the expenses were mostly backed by self-made vouchers - HELD THAT:- Though, there is no legal bar on challenging an agreed addition, but the fact of the matter is that a valid challenge can be laid before the appellate authorities only if such an admission before the AO was not in consonance with law. If, on the other hand, an admission is based purely on factual matrix, then the assessee cannot challenge the same before the appellate authorities with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... business in the name and style of M/s. S.M. Kadam. Return was filed declaring total income at ₹ 9,40,760/-. In the assessment proceedings, the AO observed that sundry creditors to the tune of ₹ 50,86,860/- were appearing in the assessee s Balance Sheet. On being called upon to furnish confirmations from the sundry creditors, the assessee furnished all except in the case of M/s. Yashoda Construction with outstanding amount of ₹ 2,69,000/-. The AO made the addition. Before the ld. CIT(A), the assessee submitted that the time limit provided by the AO was too short for enabling him to file necessary confirmations. The assessee furnished copies of Profit and Loss Account and Balance Sheet of M/s. Yashoda Construction, in which ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... raise any doubt over it. Considering the above facts, I order to delete the addition. 5. The only other ground is against confirmation of ad hoc disallowance of ₹ 25,000/- out of expenses. 6. The facts apropos this ground are that the assessee debited ₹ 92,65,070/- towards Salary to labourers. The AO found certain infirmities in the details furnished in as much as the expenses were mostly backed by self-made vouchers. The assessee agreed for ad hoc disallowance of ₹ 25,000/- before the AO, which addition was made and came to be countenanced in the first appeal. Now the assessee is aggrieved by the confirmation of such an addition. 7. Having heard both the sides and perused the relevant material on record, it is ob ..... X X X X Extracts X X X X X X X X Extracts X X X X
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