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TMI Blog2022 (2) TMI 107X X X X Extracts X X X X X X X X Extracts X X X X ..... side of the turnover. Same reasoning applies qua assessee's audit fee payment without non-deduction of TDS as well. As decided in Indwell Constructions Vs. CIT [ 1998 (3) TMI 121 - ANDHRA PRADESH HIGH COURT] that such disallowances/additions are no more exigible in case of estimation of gross receipts of an assessee. We lastly refer to landmark decision in Malabar Industrial Co. [ 2000 (2) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2012-13 arise from the PCIT-Hyderabad-4's separate orders dated 26-03-2021 23-03-2021 passed in DIN Order No. ITBA/REV/F/REV5/2020-21/1031782779(1) 1031685969(1), involving proceedings u/s. 263 of the Income Tax Act, 1961 [in short, 'the Act']; respectively. Heard both the parties. Case files perused. 2. We notice at the outset that the PCIT's impugned Section 263 revis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s) dt. 26-12-2016. The Assessing Officer thereafter framed his impugned twin assessments on 26-04-2015 accepting the income(s) returned at the assessee's behest. It is in this backdrop of facts that the learned PCIT holds in his Section 263 revision orders in issue that on account of the assessee having not deducted TDS, audit fee and difference in turnover of ₹ 35,95,785/- in AY. 2011-1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tands covered in the foregoing estimation of income being on debit side of the turnover. Same reasoning applies qua assessee's audit fee payment without non-deduction of TDS as well. We quote hon'ble jurisdictional high court's decision in Indwell Constructions Vs. CIT [232 ITR 776] (AP) that such disallowances/additions are no more exigible in case of estimation of gross receipts of a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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