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TMI Blog2018 (8) TMI 1763X X X X Extracts X X X X X X X X Extracts X X X X ..... ening balance of work in progress of subsequent year then the addition made by the AO for the year under consideration would not ipso facto amount to concealment of particulars of income. The explanation of the assessee that there may be a discrepancy in the information obtained by the AO and analyzing the same when the assessee has already declared the total receipts more than the total receipts as per the information furnished by the departments, then in considering the totality of the facts and circumstances of the case, we find that all these explanations of the assessee would constitute a bonafide explanation though the same may not be accepted for the purpose of addition in quantum proceedings - Decided in favour of assessee. - ITA N ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... A) but could not succeed. 3. Before us, the ld. A/R of the assessee has submitted that the AO has made the addition on the basis of the details collected from the Government departments about the work orders, date of inspection and payments made by them from time to time to the assessee. Thus the AO found that there is understatement of closing work in progress by the assessee to the extent of ₹ 14,25,059/-. The ld. A/R has submitted that the AO has made the addition by considering the information obtained from various departments as per which the total receipts from the contract work was considered at ₹ 4,26,84,832/- whereas the assessee had declared the total receipts at ₹ 4,61,66,265/-. Therefore, the addition made b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion made by the AO is based on the estimation as the details provided by the departments are not the complete details. He has thus pleaded that the addition be deleted. 3.1. On the other hand, the ld. D/R has relied upon the orders of the authorities below and submitted that the addition made by the ld. CIT (A) on account of suppression of closing work in progress has been confirmed by the ld. CIT (A) as well as by this Tribunal and, therefore, it is a clear case of concealment of particulars of income as the said closing work in progress has not been shown in the Profit Loss account of the assessee. The AO has detected this suppression of closing work in progress by conducting an enquiry from the concerned departments and, therefore, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee has not claimed the said amount of ₹ 14,25,059/- as part of the opening balance of work in progress of subsequent year then the addition made by the AO for the year under consideration would not ipso facto amount to concealment of particulars of income. The explanation of the assessee that there may be a discrepancy in the information obtained by the AO and analyzing the same when the assessee has already declared the total receipts more than the total receipts as per the information furnished by the departments, then in considering the totality of the facts and circumstances of the case, we find that all these explanations of the assessee would constitute a bonafide explanation though the same may not be accepted for the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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