TMI Blog2022 (8) TMI 854X X X X Extracts X X X X X X X X Extracts X X X X ..... t reflected in their confirmation. Assessee has also produced the copy of account which evidences the payment of Rs. 99,000/- made to M/s. T. R. Chadha Co. in subsequent financial year aforesaid contention of the assessee has not been controverted by Revenue. Considering the totality of the aforesaid facts, we are of the view that no addition was called for more so, when no evidence about the expenses being bogus in nature has been brought on record by the Revenue. We, therefore, direct the deletion of addition made by AO. Addition payable to M/s. P. Meera Anusha, it is the contention of the assessee that she is an employee of State Govt. on deputation to the company and as per the understanding with State Govt., assessee is required t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ring loss of Rs.6,35,42,251/-. The case was selected for scrutiny and, thereafter, assessment was framed u/s 143(3) of the Act vide order dated 21.12.2018 and the total loss was determined at Rs.6,33,08,451/-. 4. Aggrieved by the order of AO, assessee carried the matter before CIT(A) who vide order dated 20.05.2019 in Appeal No.10450/18-19 dismissed the appeal of the assessee. Aggrieved by the order of CIT(A), assessee is now in appeal and has raised the following grounds: 1. That the Ld. CIT(A) failed to appreciate the fact that the Ld. AO has erred on facts and in law in making addition of Rs.2,33,800/- u/s 68 on account of non-confirmation of credit balances Rs.99,000/- payable as provision for internal audit to TR Chadha and Co. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... owed to filed additional evidence, if so, required for proper prosecution of the case, based on the facts and circumstances, which has not been or cannot be educed or filed before lower authorities either because proper and sufficient opportunity was not provided or because it was not solicited or its need was not appropriated. 5. Before us, at the outset, Ld. AR submitted that though the assessee has raised various grounds but the sole controversy is with respect to making of addition of Rs.2,33,800/- u/s 68 of the Act. 6. During the course of assessment proceedings, AO on perusing the details of the sundry creditors noticed that assessee had shown Rs.99,000/- payable to M/s. T. R. Chadha Co. and Rs.1,34,880/- payable to M/s. P. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d 01.04.2015 to 31.03.2016 but M/s. T. R. Chadha Co. has raised the bill in Financial Year 2016-17 as the assignment of internal audit was completed in F.Y. 2016-17 and therefore, they had not reflected the amount of internal audit fees in their books of accounts in F.Y. 2015-16. She further submitted that the confirmation of Rs. 99,000/- given by T. R. Chadda Co. on 04.07.2015, which is noted by the AO in the order, was with respect to the internal audit fees paid to them for A.Y. 2015-16. She further submitted that while making provision for audit fees, the assessee had deducted TDS and the said payment was made in subsequent year. In support of her contentions, she pointed to the copy of ledger account placed in the paper book. She t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... evident from the details furnished in paper book. She further submitted that aforesaid payments are not in doubt and therefore there is no reason in making its additions. 10. Learned DR on the other hand supported the order of lower authorities. 11. We have heard the rival submissions and perused the material available on record. The issue in the present ground is with respect to the additions namely addition of Rs.99,000/- and Rs.1,34,880/-. With respect to the payment of Rs.99,000/-, it is the contention of the assessee that the amount of Rs.99,000/- was made as a provision entry for F.Y. 2015-16 relevant to A.Y. 2016-17 towards internal audit fees payment to M/s. T. R. Chadha Co., who the internal auditors of the company. Since ..... X X X X Extracts X X X X X X X X Extracts X X X X
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