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TMI Blog2022 (2) TMI 1191X X X X Extracts X X X X X X X X Extracts X X X X ..... s for fluctuation in the Gross profit/Net profit ratio and fall in the same, but the said fact on a standalone basis can by no means justifiably lead to the conclusion that the assessee had inflated expenses for facilitating suppression of his business income. In case the assessee's claim for deduction of expenses is not supported by the requisite documentary evidences, then, the same would be liable to be disallowed by the A.O. However, we cannot remain oblivious of the fact that the Assessing Officer before drawing adverse inferences as regards the assessee's claim of expenses is obligated to specifically point out those expenses which as per him are not supported by the requisite corroborating documentary evidences. AO in t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nst the order passed by the CIT(Appeals)-I, Raipur dated 16.05.2016, which in turn arises from the order dated 25.02.2015 passed by the A.O under Sec. 143(3) of the Income-tax Act, 1961 (in short 'the Act') for assessment year 2012-13. Before us the assessee has assailed the impugned order on the following grounds of appeal: 1. Because, the Ld. Commissioner of Income Tax (Appeals) erred in law as well as on facts while confirming the lump sum addition of ₹ 2,50,000/- made by the Ld. Assessing Officer. 2. Because, the Ld. CIT(Appeals) has erred in overlooking and summarily rejecting the detailed statements of facts submitted along with written submission of appeal and accepted the incorrect version of the learned Asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2010-11 1075.19 72.14 6.71% 20.87 1.94% It was further observed by the Assessing Officer that the assessee had debited a heavy amount of ₹ 12,57,438/- on account of wages and salary paid to workers a/w salary expenses of ₹ 1,47,300/-. On perusal of the records, it was observed by the Assessing Officer that not only the assessee had failed to maintain proper salary register, but even the vouchers which were produced by him did not contain the requisite details i.e. working hours, duration of work, bifurcation of skilled/semi-skilled labour etc. As can be gathered from the assessment order, it was further observed by t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Assessing Officer, therein, at the very face of it does not instill any confidence as regards the view taken by him that the assessee had inflated certain expenses for suppressing his income. In our considered view, though there can be multiple reasons for fluctuation in the Gross profit/Net profit ratio and fall in the same, but the said fact on a standalone basis can by no means justifiably lead to the conclusion that the assessee had inflated expenses for facilitating suppression of his business income. In fact, we find that the assessee on being confronted with the comparative fall in its Gross profit/Net profit ratios had categorically explained that the same had occasioned due to heavy competition in the market of CI Casting and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... efore drawing adverse inferences as regards the assessee's claim of expenses is obligated to specifically point out those expenses which as per him are not supported by the requisite corroborating documentary evidences. Now, the Assessing Officer in the case before us had though pointed out that vouchers produced by the assessee did not contain requisite details, i.e., working hours, duration of work, bifurcation of skilled/semi-skilled labour etc., but then, we cannot be oblivion of the fact that there is no whisper of any single instance of expenditure in the body of the assessment order which as per the Assessing Officer could not be verified. In our considered view, a generalized observation as regards the non-verification of the as ..... X X X X Extracts X X X X X X X X Extracts X X X X
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