9911796707
TMI Blog2018 (12) TMI 1459X X X X Extracts X X X X X X X X Extracts X X X X ..... in support of the order of the Ld. CIT(A) for the Assessment Year (A. Y. )2010-11. 2. All the grounds of appeal are related to the under statement of receipts as per TDS Certificate and the P&L account on account of redrying and threshing charges. The assessee is engaged in the activity of redrying and threshing of tobacco. For the A. Y. 2006-07, the assessee filed the return of income declaring total income of Rs. 1,60,64,730/- and the assessment was completed u/s 143(3) on total income of Rs. 1,72,80,022/-. Subsequently, the AO reopened the assessment for discrepancy in the redrying and threshing charges paid as per TDS certificates and the receipts offered in the P&L account. The AO found that a sum of Rs. 1,07,32,284/- was the differe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the job work of other companies also. During the assessment year, the assessee undertook the job work of redrying and threshing of tobacco to the tune of 2,49,18,726kgs of tobacco with six companies and received a sum of Rs. 13,29,85,815/- and out of which M/s Somasundaram has issued 2,06,01,981kgs involving the contract value of Rs. 10,86,24,602/- for threshing and happens to be the premier customer in conferring business of 82% of entire threshing operations conducted by the assessee. Due to recession in tobacco trade, the assessee has given additional discount to M/s Somasundaram for procuring the business and the payments made by M/s Somasundaram to the assessee company as per TDS Certificates was before additional discount allowed by t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the additional discount offered by the assessee was admitted by M/s Somasundaram in their returns of income and paid taxes. The Ld. CIT(A) further observed that due to recession in the tobacco market, the assessee has allowed additional discount to M/s Somasundaram who is bulk customer and the receipts in the TDS certificates were before allowing the additional discount. There is no dispute that the assessee has allowed the additional discount and the recipient M/s Somasundaram has admitted the additional discount in the returns of income and offered for taxation. The office of the Sr. AR has filed a copy of AO's letter dated 16. 08. 2017 addressed to Sr. AR confirming that M/s Somasundaram, the recipient has admitted the entire discoun ..... X X X X Extracts X X X X X X X X Extracts X X X X
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