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TMI Blog2023 (3) TMI 856X X X X Extracts X X X X X X X X Extracts X X X X ..... hoc basis without specifying particular mistake. Such approach cannot be supported by noting that there is slight fall in the GP ratio as done by the ld. CIT (A). Accordingly, we set aside the orders of the authorities below and decide the issue in favour of the assessee. - ITA No.6110/Del./2018 - - - Dated:- 16-3-2023 - Shri Shamim Yahya, Accountant Member And Ms. Astha Chandra, Judicial Member For the Assessee : Shri S. Krishnan, Advocate For the Revenue : Ms. Indu Bala Saini, Sr. DR ORDER PER SHAMIM YAHYA, ACCOUNTANT MEMBER : This appeal by the assessee is directed against the order of ld. CIT (Appeals)-20, New Delhi dated 23.07.2018 pertaining to the Assessment Year 2014-15. 2. The grounds of appeal tak ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e arbitrary and ad-hoc addition of Rs.87351/-out of business promotion expenses in the name of 'plugging the leakage of revenue' without any legally or factually sound basis. 7. That the Ld. CIT (A) erred in law and on facts in not properly appreciating the explanation furnished by the assessee during appellate proceedings and rejecting the same in a routine manner and also not considering the case law on the issue in respect of additions of Rs.3,00,000/-, Rs. 2,00,000/- Rs. 87351/- as referred to in aforesaid grounds No.4, 5 6. 3. One issue in this appeal relates to difference between contract receipts as compared with Form 26AS. 4. AO in the assessment order noted that assessee could not offer any explanation, hence ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d. Counsel of the assessee submitted that his plea on this account is very limited that reconciliation should be done with the entries of 26AS assessee s books and the assessee should be permitted to explain the same before the AO. 8. We agree with the above proposition and accordingly direct the AO to examine the issue of difference between Form 26AS and the books of accounts after giving assessee appropriate opportunity of being heard. 9. Other ad hoc disallowance of Rs.3,00,000/- on the issue of disallowance out of sub-contractor charges expense. AO noted that assessee has debited Rs.6,37,62,122/- as sub-contractor expenses. Assessee was asked to submit vouchers but AO noted that the assessee could not substantiate with adequate ..... X X X X Extracts X X X X X X X X Extracts X X X X
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