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2022 (9) TMI 462

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..... originated against the order of the Income Tax Officer, Ward-2, Srinagar (in brevity the AO), order passed u/s. 143(3) of the Act, date of order 21.12.2009. 2. Brief facts of the case are that the assessee is a manufacturer of distribution transformers, conductors and steel tubular poles. During the year under consideration, sale amount of Rs. 53,13,804/- on which the gross profit was declared amount to Rs. 1,32,859/- which is worked out @ 2.5%. In assessment proceeding the addition was made by disallowing the different expenses total amount as of Rs. 7,99,997/- which was added with the total income of the assessee. Also, the disallowance of expenses u/s. 40(a)(ia) for non-deduction of TDS u/s. 194C for payment to transporter amount of Rs .....

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..... ted under the accounting head 'advance against supplies'. The total imprest during the year amounted to Rs. 7,83,130/- for which the partner has rendered accounts at the year end and accordingly expenses incurred out of such imprest booked on 31-03-2007'. Details of such expenses are enclosed". Your honour, the above explanation is self-explanatory. Actually, during the year, the assessee received orders for erection & installation of tubular poles in far flung areas under the Gods rural electrification scheme. Since the men & material required for erection & installation of such poles was moved near the site, the expenses for the purpose were incurred through imprest given to partner who rendered the account at the year end. .....

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..... details & information & explanation submitted to Ld. ITO & CIT (A), the addition needs to be deleted." 5. The Ld. Sr. DR argued and relied on the order of revenue authorities and not made any strong objection against the submission of the assessee. 6. We considered the documents available in the record & the orders of revenue authorities. The assessee had paid the expenses through banking channel. The amount was incurred out of such imprest booked on 31.03.2007, the details explanation was filed by the assessee, supra. The expenses are paid in job-site and all the expenses are accumulated from different site to head office which was entered in books of accounts on dated 31.03.2007. The AO did not find any specific lacuna or did not point .....

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