TMI Blog2024 (3) TMI 251X X X X Extracts X X X X X X X X Extracts X X X X ..... pparently the said concern was paying commission of about 1% to unidentified brokers for arranging such transactions - assessee denied the allegation of receiving a contract - AO received the information that the contract price was Rs. 16,93,71,626/-, but he accepted the contract receipts of Rs. 29,65,16,795/- and estimated profit at 8% and made addition - CIT(A) deleted the addition HELD THAT:- W ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ur-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 were carefully perused. 4. Briefly stated the facts of the case are that the assessee filed its return of income electronically on 29 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rom 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 concern was paying commission of about 1% to unidentified brokers for arranging such transactions. The entire activity is bogus activity and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ommission 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 findings of the CIT(A) cannot be faulted with. 7. In the result, appeal of the Revenue is dismissed. Order pronounced in the Open Court on 0 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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