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TMI Blog2024 (2) TMI 397X X X X Extracts X X X X X X X X Extracts X X X X ..... ER PER : HONOURABLE MRS. JUSTICE MAUNA M. BHATT 1. This appeal under Section 260A of the Income Tax Act, 1961 (for short 'the Act') by the Revenue is filed challenging the order dated 16.09.2022 passed by the Income Tax Appellate Tribunal, Rajkot (for short 'ITAT') in ITA No. 554/RJT/2015 for assessment year 2012-13. 2. The assessee who is a private company and engaged in the business of manufa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee. 3.2 Against the order of the CIT(A), the appellant revenue preferred appeal before the ITAT and the ITAT vide order dated 16.09.2022 dismissed the appeal of the revenue, aggrieved by which the present appeal is filed, proposing the following substantial question of law: "Whether the Hon'ble Tribunal was justified in deleting the addition of Rs. 42,98,84,771/- made by the AO u/s. 41(1) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e that the difference in the amount shown by the assessee as liability viz of viz the amount shown by the party M/s Kabra Brother is arising mainly on account of the entries recorded in the books of accounts. The assessee has issued letter of credit to the party which can be verified from the letter of the bank placed on pages 99 to 100 of the paper book. The assessee was liable to make the paymen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the learned CIT-A. Thus, we do not find any infirmity in the order of the learned CIT-A and accordingly we uphold the same. Thus the AO is directed to delete the addition made by him." 6.1 From the facts stated hereinabove, it is clear that the additions under Section 41(1) were made for the differences which arose on account of only book entries. Admittedly, the assessee had actually made th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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