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2024 (3) TMI 251

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..... Shri Neeraj Singh, CA ORDER PER N.K. BILLAIYA, AM This appeal by the Revenue is preferred against the order of the CIT(A), Kanpur-4, dated 16.08.2021 pertaining to A.Y. 2011-12. 2. The solitary grievance of the Revenue is that the CIT(A) erred in deleting the addition made by the AO to the tune of Rs. 2,37,21,344/-. 3. Representatives of both the sides were heard at length. The case records w .....

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..... entities. As per the evidence available with this office in F.Y.2010-11 as part of the bogus activity, the said company took a contract from M/s VNR Infra and in turn awarded it to M/s Rishab Buildcon (P) Ltd, Delhi on back to back basis for an amount of Rs. 29,65,16,795/-. The assessee despite repeated opportunity could not justify the transactions. It is also noticed that apparently the said con .....

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..... what was the contract receipts was it 29.65 crores or 16.93 crores? Further, when the MD of Totem Infrastructure Ltd. has stated that the commission ranges from 0.25% to 1%, then we fail to understand what is the basis for estimating the profit at 8%. In our considered view, the entire addition has been made on surmise and conjecture without there being any demonstrative evidence; therefore, the .....

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