TMI Blog2021 (10) TMI 875X X X X Extracts X X X X X X X X Extracts X X X X ..... en a clear cut finding wherein it is categorically mentioned that the Assessing Officer never disputed the fact of deposit of tax deducted at source before the due date of filing the Income Tax Return for the subject year. CIT(A) rightly held that once the AO was directed to verify the amount on which tax has been paid before the due date of filing the return of income and allow the same in the fi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d circumstances of the case and in law, the Ld. CIT(A) has erred in allowing relief of ₹ 38.57 crores on expenditure which has neither been ascertained or crystallized during the year and nor was the TDS deduced during the year. 3. The assessee is a Public Limited Company and is engaged in the business of manufacturing and sale of two wheelers since 1984. The assessee filed return of in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 62 crores) to the returning amount. Against the final assessment order, the assessee filed appeal before the Tribunal which was disposed off vide order dated 13/6/2014 wherein the majority of the aforesaid additions/disallowances to be extent of ₹ 3279.25 crores were deleted by the Tribunal. Further, additions/disallowances to ₹ 68.60 crores were set aside by the Tribunal to the file o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee. 4. The Ld. DR submitted that the CIT(A) erred in allowing relief of ₹ 38.57 crores on expenditure which has neither been ascertain or crystallized during the year and nor was the TDS deducted during the year. The Ld. DR relied upon the assessment order. 5. The Ld. AR relied upon the order of the CIT(A). 4. We have heard both the parties and perused all the relevant materials a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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