9911796707
TMI Blog2022 (11) TMI 1249X X X X Extracts X X X X X X X X Extracts X X X X ..... he orders has been furnished by the assessee, the Income Tax Inspector was deputed to cause enquiries at the address is given by the assessee, but such addresses were found to be incorrect. In the circumstances, there is no course open to the Assessing Officer to verify the alleged expenditure - So also in respect of the other expense said to have been paid to the marketing executive towards salary incentives etc., no occasion for such payments seems to be probable because admittedly the commercial activity of the assessee had not commenced and not even a single plot was sold or book for sale during the relevant assessment year. All the circumstances would go to show that there is no possibility to verify the expenses and therefore it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earned Assessing Officer passed an order dated 28/3/2013 under section 143(3) read with section 263 of the Act determining the income of the assessee at Rs. 5,69,100/-. Assessee filed appeal against this order also. 3. It could be culled out from the impugned order that in the hearing of the appeal against the order passed under section 143(3) read with section 263 of the Act, the assessee submitted that inasmuch as the original order under section 143(3) of the Act was set aside by the Ld. CIT-VI under section 263 of the Act, appeal against the same does not survive and, therefore, proceeded with the appeal against the order under section 143(3) read with section 263 of the Act. 4. Though there are several grounds and additions invol ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ns unproved; and the payment of Rs. 35,75,279/- as marketing executive salary, incentives etc., to 313 persons is not probable because the commercial activity of the assessee has not commenced and not even a single plot was sold or booked for sale during the year. 8. Before the Ld. CIT(A) also no iota of evidence was adduced by the assessee in support of the payments of Rs. 54,50,525/- said to have been paid by the assessee and no confirmation letters are forthcoming. In respect of payment of Rs. 35.75 lakhs to 313 marketing executives also Ld. CIT(A) did not believe the version of the assessee because the commercial operations of the assessee have not yet commenced and no plot was sold or booked for sale despite having such a large numb ..... X X X X Extracts X X X X X X X X Extracts X X X X
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