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2021 (10) TMI 725

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..... ountant Member: The present appeal has been filed by the revenue against the order of ld. CIT (A)-6, Delhi dated 23.06.2017. 2. Following grounds have been raised by the revenue: "1. Whether on facts and in circumstances of the case, the Ld. CIT(A) is legally justified in deleting the disallowance of Rs. 1,81,50,000/- u/s 37 (1) of the Income Tax Act, 1961 (the Act) on account of 'job char .....

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..... assessee?" 3. None attended on behalf of the assessee. Since, it is believed that dispensation of justice will not be delayed when the same can be indulged on going through the record, we hereby proceed with adjudication of the single issue of disallowance of expenses. 4. Facts of the case in brief are that the assessee e-filed return of income on 30.09.2013 declaring an income of Rs. 91,42,604/ .....

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..... furnish the ledger account alongwith supporting evidence in respect expenses debited to Prof it and Loss account amounting to Rs. 24.60 crores on account of wage/salary and job charges and also to justify the increase in expenses as compared to last year. 3.2 In response, the assessee furnished the reply on 22.03.2016 whereby enclosed ledger account of wages, salary and job charges. The AR in t .....

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..... that the job work charges expenses claimed by the assessee are extremely excessive and therefore, 10% of such charges, which comes Rs. 1,81,50,000/-, are disallowed and added to the assessee's taxable income." 6. Before the ld. CIT (A), it was argued that the increase in 'Job Work Expenses' is directly proportional to the 'Job Work Revenue'. The details are as under: Particulars FY 12-13 (INR) .....

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..... of the company increased from Rs. 6.74 crores to Rs. 36.53 crores and so as the expenses increased from Rs. 6.45 crores to 24.60 crores. Hence, it can be said that the expenses have been increased proportionately. Further, the ledger and books of accounts have been examined by the Assessing Officer and no discrepancy could be brought out to the fore. Having accepted the books of accounts, disallo .....

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