9911796707
TMI Blog2022 (7) TMI 219X X X X Extracts X X X X X X X X Extracts X X X X ..... this appeal has taken the following grounds of appeal: "1. That on the facts and in the circumstances of the case, the learned Commissioner of Income Tax (Appeals) erred in upholding the DCIT's assessment on a total income of Rs 37,03,780/- against the Income of Rs 13,017,18/- (Rs 9,06,444/- as reflected in the Assessment Order and Rs.3,95,274/- accepted by the Appellant itself.) 2. That on the facts and in the circumstances of the case, the learned CIT (A) erred in upholding the addition of Rs.24,02,058/- on account of disallowance u/s 40(a)(ia) of the Income Tax Act 3. That on the facts and in the circumstances of the case, the learned CIT(A) failed to appreciate that the addition of Rs.23,52,059/- has already been added back ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vance Tax Rs.5,50,000/- and Regular Assessment Tax Rs.24.41,680/-). 8 That on the facts and in the circumstances of the case, the learned CIT(A) erred in disregarding the fact that the appellant had duly deducted tax on Rs. 50,000 paid to Shri Puran Kumar Roy and deposited the same before the due date of filing return u/s 139(1). 9. That the appellant craves leave to add, alter and/or amend the grounds of appeal at the time of hearing." 2. Ground No.1 - Ground No.1 is general in nature. The assessee has raised all the issues collectively in this ground, whereas the assessee in subsequent grounds has contested each of the grounds separately. Therefore, no separate adjudication is required in respect of Ground No.1. Our separate adjud ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... missions of the ld. counsel for the assessee that the amount has been added back in the subsequent year and further the explanation given that the amount was not paid during the year but only a book entry was made, however, since there was a dispute, hence, the TDS was not deducted and subsequently, the entry was reversed. Further, it has been claimed that the TDS was duly deducted on the remaining amount of Rs.50,000/- and the same was duly paid to the Government account. We are of the view that the facts need to be verified by the Assessing Officer. Ff the contention of the assessee is found correct then no disallowance to be made by the Assessing Officer on this issue. 4. Ground Nos.3 to 8 - Vide Ground Nos.3 to 8, the assessee has disp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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