GOVINDAM BRJ INFRA PROJECTS PRIVATE LIMITED,JAIPUR vs. ACIT/DCIT CIR-6,JPR, JAIPUR

vkns'k@ORDER PER: DR. S. SEETHALAKSHMI, J.M.

These are two appeals filed by the assessee against two separate orders of ld. CIT (A), National Faceless Appeal Centre (NFAC) Delhi dated 24.03.2025 passed under section 250 of the I.T. Act, 1961, for the assessment years 2017-18 and 18- 19. 2. The assessee has raised the following grounds of appeal :-

& 1115/JPR/2025 Govindam Brj Projects Pvt. Ltd., Jaipur. AY 2017-18 : “1. On the facts and in the circumstances of the case and in law, the learned AO and CIT (A) erred in making ad-hoc disallowance of 10% of labour expenses i.e. Rs. 9,71,272/- without pointing out specific defects or conducting proper verification. The disallowance is arbitrary and not based on any material evidence establishing that the expenses were not genuine or inflated.

2. On the facts and in the circumstances of the case and in law, the learned AO and CIT (A) have erred in treating sundry creditors of Rs. 18,24,000/- as unexplained cash credit based on mere suspicion without establishing that the creditors are non- existent. The learned authorities failed to discharge their burden of proof after the Appellant provided primary details regarding genuineness of transactions.

3. On the facts and in the circumstances of the case and in law, the learned AO erred in initiating penalty proceedings u/s 270A(1) r.w.s. 270A(9)(a) and u/s 271 AAC. The penalty proceedings are premature and bad in law as the substantive additions are disputed and not sustainable.

4. On the facts and in the circumstances of the case and in law, the learned AO and erred in charging interest u/s 234B and 234D which are consequential in nature. The interest charges are not sustainable once the additions are deleted.

5. The appellant craves leave to add, amend, alter, modify or withdraw any all of the above grounds of appeal

before or at the time of hearing of the appeal. “

1. The ld. CIT (A) erred in law and on facts in upholding the action of the ld. AO in rejecting the books of accounts u/s 145(3) of the Income Tax Act, 1961, when the books of accounts were regularly maintained and audited under section 44AB. The AO failed to point out any specific defects in the books of accounts that would warrant rejection u/s 145(3). The rejection was mechanical and arbitrary without proper application of mind.

2. The ld. CIT (A) erred in law and on facts in confirming the arbitrary estimation of income at 8% of turnover and making addition of Rs. 91,05,708/- without considering the nature of infrastructure and road construction business which involves low profit margins. No comparable cases or industry standards were considered for adopting 8% profit rate. The estimation was made in a mechanical manner without proper analysis of the business model.

& 1115/JPR/2025 Govindam Brj Projects Pvt. Ltd., Jaipur.

3. The ld. CIT (A) erred in dismissing the ground relating to violation of principles of natural justice when he show cause notice u/s 143(3) dated 19.04.2021 provided only 7 days’ time to reply by 26.04.2021. This was the period of 2nd wave of Covid-19 and prevailing lockdown restrictions in Rajasthan. Assessee also submitted request letter dated 26.04.2021 requesting to adjourn the case for next 15 days due to covid-19 related restrictions. But the ld. AO did not consider the adjournment request with genuine reasons and passed the assessment order on 28.04.2021.

4. The ld. CIT (A) failed to consider that Infrastructure projects involve multiple sub-contractors and complex payment arrangements. The nature of construction business requires purchase of diverse materials and services. Government contracts have specific compliance requirements affecting profit margins.

5. The ld. CIT (A) erred in confirming the addition of Rs. 91,05,708/- which is Excessive compared to the declared income of Rs. 70,33,180/- and not supported by any material evidence of income suppression. It is based on presumptions rather than facts and also disproportionate to the nature and size of the business.

7. The ld. CIT (A) erred in not properly considering the grounds relating to initiation of penalty proceedings u/s 270A, 271A and 272A(1)(d), which are not sustainable when the primary addition itself is not justified.

3. We find that both these appeals filed by the assessee are delayed by 68 days each. The assessee has filed applications submitting therein the reasons for delay in filing the appeals and prayed for condonation of delay. In support of the applications, the assessee has also filed an Affidavits dated 4th August, 2025 for condonation of delay, which is being reproduced hereunder :- “AFFIDAVIT I, Shankar Lal Sharma, aged 54 years, son of Shri Bhagwani Ram, Director of M/s. Govindam BRJ Infra Projects Private Limited (PAN: AAECG9877G), having its registered office at Plot No. 718, Flat No. 201, Anupam Apartment, Gopalpura Bypass, Mahaveer Nagar, Jaipur-302018, do hereby solemnly affirm on oath as under :-

1. 1. That I am the duly authorized representative of the Appellant Company and am fully conversant with the facts and circumstances of the case and am competent to swear this affidavit.

2. That the AO passed the assessment order for the AY 2017-18 on dated 28.12.2019 u/s 143(3) of the IT Act, 1961 by making addition of Rs. 28,28,258/-.

3. That against the above referred order, assessee company filed appeal in Form-35 before Ld. CIT (A) on 27.01.2020. The ld. CIT (A) issued multiple hearing notices but the assessee company could not file written submission due to lack of proper legal guidance.

4. That the CIT (A)/NFAC, Delhi passed the order u/s 250 dated 24.03.2025 and dismissed the appeal, which was received by the Appellant Company on or around 25.03.3035 through the registered email address.

5. That our consultant Advocate Dinesh Sharma initially opined that since the CIT (A) had dismissed the appeal as “not seriously pursued” rather than on merits, there might be scope for filing revision u/s 264 before the PCIT.

6. That since our counsel Advocate Dinesh Sharma was not properly responding about the rate of our case, we approached CA Om Prakash Rupani on 29.07.2025 to advice in the matter. He, thereafter checked the status of our case and suggested to file an appeal before ITAT^ with application for condonation of delay.

7. That the delay was not willful, intentional, or due to any negligence on the part of the Company, but was due to bona fide reasons and circumstances beyond our control. Sd/- Deponent (Shankar Lal Sharma) VERIFICATION I, Shankar Lal Sharma, director of M/s. Govindam BRAJ Infra Projects Private Limited do hereby verify that the contents of the above affidavit are true and correct to the best of my knowledge and belief. Sd/- The affidavit filed by the assessee for condonation of delay for the AY 2018-19 is the same as in AY 2017-18, except the quantum of addition and date of assessment order passed by the AO. Therefore, for the sake of repetition, the same are not being reproduced.

ITA NO. 1114/JPR/2025 AY 2017-18 :

6. At the time of hearing before us, the ld. AR of the assessee submitted his ground-wise written submission as under :- “ Ground No. 1 On the facts and in the circumstances of the case and in law, the learned AO and CIT(A) erred in making ad-hoc disallowance of 10% (Rs. 9,71,272) out of total wages expenses of Rs. 97,12,726/- without pointing out specific defects or conducting proper verification. Further the Ld. AO has not specified the provision of the Income-tax Act, 1961 under which such disallowance has been made, rendering the addition unsustainable in law. Brief Facts: The Appellant is engaged in the business of civil construction activities. The Appellant filed return of income for A.Y. 2017-18 on 07.11.2017 declaring total income of Rs.20,20,670/- on Turnover of Rs. 7,75,98,792/-. The case was selected for scrutiny assessment under CASS andthe Ld. Assessing Officer completed the assessment u/s 143(3) vide order dated 28.12.2019, determining the total income at Rs. 48,48,930/-. The Appellant had claimed wages expenses amounting to Rs. 97,12,726/-. The Ld. AO did not consider the cash payments supported by handmade vouchers and disallowed 10% of total cash payments made for labour expenses, resulting in disallowance of Rs. 9,71,272/-on ad-hoc basis. Submission: 1. It is humbly submitted that it has not been mentioned by the Ld. A.O or Ld. CIT(A) that under which section of the Income Tax Act, the ad-hoc disallowance has been Judicial Precedents:

 Smt. SudhaLoyalka C/o M/s. RRA Taxindia vs. ITO - [2018 (7) TMI 1892](ITAT Delhi): it was held that, “Para 6, After hearing both ….. In our considered opinion, the sustaining of impugned addition is not justified due to the following reasons:- i) It has not been mentioned either by A.O or by Ld. CIT(A) as to under which section of the Income Tax Act, these closing credit balances appearing as on 31.03.2012 could be added. Therefore, non-mentioning the precise provision of law makes the impugned addition bad in law. "

 Neeraj Paliwal vs. ITO - [2021 (12) TMI 584] (ITAT Jodhpur): It was held that,

“12. Having considering the rival contentions and carefully perused the material placed on record. From perusal of the record, we observed that the order of the AO as well as that of the CIT(A) that they have not specifically mentioned as to under which section of the Act the additions have been made. In this regard, we draw strength from the decision of the Coordinate Bench of the Delhi ITAT in the case of Smt. SudhaLoyalkavs ITO, ITA No. 399/De1/2017.

- In the construction industry, it is a common practice to make cash payments to daily- wage labourers, many of whom are illiterate and not in a position to sign elaborate receipts.Handmade vouchers/wage sheets are standard documentary evidence in such circumstances.

- Affixing of revenue stamps is only a procedural requirement under the Stamp Act for receipts exceeding a prescribed limit. Its absence may be at best a technical lapse but does not make the underlying transaction non-genuine

- Laborers engaged in construction sites are generally migratory, daily-wage earners and it is practically impossible to obtain detailed identification for each casual laborer.

- Percentage of labour cost to gross receipts varies depending upon the nature of project, labour intensity, and stage of execution. Merely because the AO feels 13% is “high” does not justify disallowance, especially without benchmarking against comparable cases.

Judicial Precedents:  Dharmendra Prasad More, Balasore vs ITO,Ward-1, Balasore (ITA/215/CTK/2022)

Facts of the case present are very similar to this case in which the Assessing Officer had disallowed 5% out of labour charges and transportation charges on the ground that the vouchers were self-made vouchers and complete details of the labourers was not available. The Ld. CIT(A) has admittedly dismissed the assessee's appeal on account of non- representation. Hon’ble ITAT allowed the appeal by stating at para 6 of the order, “6. We have considered the rival submissions. A perusal of the facts in the present case shows that the disallowance as made by the AO at 5% out of labour charges and transportation expenses are clearly on adhoc basis. If the AO had found that there was discrepancy in the vouchers produced, it was very much open to the AO to identity the defect and disallows the same. This has not been done. Also the books of account of the assessee have not been rejected. The assessee is in the business of clearing & forwarding agent in respect of cement. This admittedly involves substantial labour charges and transportation charges. Considering these facts, we are of the view that the adhoc disallowance made by the AO is uncalled for.” In the case of Pr. CIT vs. R.G.Buildwell Engineers Ltd., (2018) 99 taxmann.com 284 (SC), the Hon'ble Supreme Court has upheld the action in deleting the adhoc disallowance by the Tribunal on the ground that there was omission to reject the books of account of the assessee. In view of it is evident that the AO’s objections are based on technicalities and presumptions, not on actual detection of bogus expenditure.No specific instance of false claim has been identified. Hence, the ad-hoc disallowance of 10% is arbitrary, unjustified, and deserves to be deleted. Ground No. 2 On the facts and in the circumstances of the case and in law, the learned AO and CIT(A) erred in treating sundry creditors as unexplained cash credit u/s 68 merely for want of PAN details and whereby making addition of Rs. 18,24,000/-. Further there is no dispute on the amount of purchase. Brief Facts:

& 1115/JPR/2025 Govindam Brj Projects Pvt. Ltd., Jaipur. The Ld. AO required confirmation of sundry creditors and found that certain creditors' confirmations did not contain PAN details. Accordingly, the Ld. AO made addition of Rs. 18,24,000/- as unexplained cash credit u/s 68 of the Act. Submission: It is humbly submitted that names, confirmations, and balances of creditors were furnished. PAN is not a mandatory requirement. Creditors are part of regular audited books.AO might have conducted independent enquiry by issue of summons u/s 131 or notices u/s 133(6) to these creditors. Law is clear that AO must attempt verification.Merely doubting due to absence of PAN does not establish non-genuineness. Further it is settled law that when purchase is not in dispute, the addition of sundry creditors cannot be made u/s 68. Judicial Precedents:  CIT v. Pancham Dass Jain, Allahabad High Court, (2006) 205 CTR (All) 444 / 156 Taxman 507 (All), judgment dated 21 Aug 2006 In this case Hon’ble Allahabad High Court (2006)upheld the decision of ITAT. Relevant para 4 of the order is reproduced hereunder: “4. The submission is misconceived. The Tribunal has recorded a categorical finding of fact based on appreciation of materials and evidence on record that the AO had accepted the purchases, sales as also the trading result disclosed by the respondent-assessee. It had recorded a finding that the aforesaid two amounts represented the purchases made by the assessee on credit and, therefore, the provisions of Section 68 of the Act could not be attracted in the present case. We fully agree with the view taken by the Tribunal on this issue, inasmuch as, on the basis of the findings recorded by it that these two amounts represented purchases made by the respondent-assessee on credit and the purchases and sales having been accepted by the Department, the question of addition of the aforesaid two amounts under Section 68 of the Act did not arise inasmuch as the provisions of Section 68 of the Act would not be attracted on the purchases made on credit.” Prayer In light of the above rebuttals and settled law, the Appellant prays that:

1. 1. The disallowance of Rs. 9,71,272/- towards labour/wages be deleted. 2. The addition of Rs. 18,24,000/- u/s 68 be deleted. 3. Interest and Penalty proceedings be quashed as premature.”

Now we adjudicate the grounds taken by the assessee as under :

Ground No. 1 relates to disallowance of Rs. 9,71,272/- @ 10% of labour expenses of Rs. 97,12,726/- on account of cash payment.

8. We have heard the rival contentions, perused the material on record and gone through the orders of the lower authorities. On perusal of the case file, in this case the sole reason given by the Assessing Officer to make the adhoc disallowance is that payments have been made in cash to the laborers whose identity cannot be established, the claim of such payments cannot be accepted in totality. The AO disallowed 10% of the claimed expenses treating it to be unverifiable. The AO has further noted in the assessment order that the cash payment made by the assessee company has been made by self made voucher / handmade vouchers wherein the assessee did not get any recipient of cash verified. Neither full address of the recipient of cash has been written nor has any proof of identification of such recipient been provided to the AO in respect of cash payment made under the head Labor payment or other heads of cash payment. The AO observed that the assessee has just tried to color its cash payment to be in accordance with law but such a huge amount of expenses made in cash has not been justified in full. The AO further observed that the company has not deducted & 1115/JPR/2025 Govindam Brj Projects Pvt. Ltd., Jaipur. TDS on all the cash payment as claimed and huge part of such cash payments remained unverified because of the reasons discussed above. The AO mentioned that the assessee had made approximately 13% of gross receipt of current financial year is made for labor payment and all such payments have been made in cash, thus not been fully verifiable for the reasons discussed above. Further, the payment made in cash was not backed with proper vouchers being handmade voucher, payment vouchers not supported with revenue stamps etc. On the contrary, the assessee submitted that the workers as mentioned in the Labor Wages Sheets were hired on daily basis for construction work and in the Labor Wages Sheets maintained, their signature or thumb impression was obtained when cash payment was made to them, the main reason for making cash payment is that they being illiterate, do not maintain any bank account. The daily wages workers are generally casual in nature who come from nearby villages/towns in city for work and these workers do not work at same place regularly. The assessee further submitted that the Labor Wages Sheets maintained contains the period of work, name of worker, type of worker, wage rate, payment made and signature or thumb impression of the workers. On perusal of the case file, we find that it is an undisputed fact that the appellant has produced all the necessary bills/vouchers, copy of ledger account related to expenses relating to civil construction activities and labour wages sheets before the AO to verify the genuineness of the expenses incurred. We do not find & 1115/JPR/2025 Govindam Brj Projects Pvt. Ltd., Jaipur. any mention in the assessment order that the AO has specifically examined the details furnished by the assessee or any specific defect was observed by theAO in any of the content of the labour wages sheets except a general comment about non mentioning of identity details of the labourers and the AO has not pointed out any specific defect in the vouchers/bill. There is also no finding that any expenditure was not found to be genuine or not related to the business. In our opinion, the Scheme of the Act does not authorize the AO to make a disallowance according to his wishes, rather it provide that he should first point out the defects in the accounts of the assessee. In the finding extracted (supra) it nowhere reveals which specific voucher was not in accordance with law. The AO has not brought on record any specific material even though complete details were filed during the course of assessment proceedings. In a just sweeping statement, the AO observed that it is noted that the payments are seen to have been made in cash to persons whose identity cannot be established and the before, the claim of such payments cannot be accepted in totality. In view of the same, 10% of the claimed expenses being Rs. 9,71,272/- are hereby disallowed as being unverifiable, which is not a correct approach and is not in accordance with law. No evidence was collected to suggest that payments were not genuine. We also take note of the reality that in civil constructions wherever laborers are hired from open market, no proof of identity is provided by such illiterate laborers and even they hesitate to receive & 1115/JPR/2025 Govindam Brj Projects Pvt. Ltd., Jaipur. payment of wages through banking channel. It is settled law that addition based upon surmises and conjectures cannot be sustained. The Hon’ble Supreme Court in the case of CIT (Bom.) vs. Walchand & Company Pvt. Ltd. in 65 ITR 381 (SC) held that “ in applying the test of commercial expediency for determining whether an expenditure was wholly and exclusively for business, the expenditure has to be adjudged from the point of view of the businessman and not of revenue. Thus, we find that Assessing Officer has made the disallowance purely on guess work and without cogent reasoning. Under these circumstances, adhoc disallowance cannot be sustained. Accordingly, we do not find any infirmity or illegality in the order of the ld. Commissioner of Income Tax (Appeals) in this regard. Accordingly we confirm the same.” 8.1 We have also noted that the AO has not resorted to the provisions of section 145 (3) of the Income tax Act, 1961 and without applying such provisions the ad hoc disallowance is not permissible. 8.2 From the perusal of record, we further observe that the AO as well as the ld. CIT (A) have not specifically mentioned as to under which section of the Act the addition has been made. In this regard, we draw strength from the decision of the Coordinate Bench of the Delhi ITAT in the case of Smt. Sudha Loyalka vs. ITO, wherein the Coordinate Bench has held as under :-

& 1115/JPR/2025 Govindam Brj Projects Pvt. Ltd., Jaipur. “ In our considered opinion, the sustaining of impugned addition is not justified due to the following reasons :- i) It has not been mentioned either by AO or by ld. CIT (A) as to under which section of the Income Tax Act, these closing credit balances appearing as on 31.03.2012 could be added. Therefore, non-mentioning the precise provision of law makes the impugned addition bad in law.

We also draw strength from decision of the Coordinate Bench of ITAT Bangalore in the case of Shree Ramareddy Ramesh vs. ITO in wherein it has been held as under :-

“ About the third amount of Rs. 30,21,961/-, we find that this is a fact that no section is mentioned by the AO or CIT (A) for making this addition and for this reason alone, the addition is bad in law as per the tribunal order cited by the learned AER of the assessee having been rendered in the case of Smt. Sudha Loyalka vs. ITO (supra) wherein it was held that non mentioning the precise section makes the addition bad in law.”

8.3 Considering the entire conspectus of case and the judicial pronouncements, we do not find favour with the views of lower authorities, consequently we delete the adhoc disallowance and allow the ground of the assessee.

Ground No. 2 relates to addition of Rs. 18,24,000/- under section 68 on account of unexplained cash credit.

Being not satisfied with the order of the ld. CIT (A), the assessee has come in appeal before the Tribunal on the grounds reproduced herein above.

1. 1. The appellant is a private limited company engaged in construction contracts for PWD and NHAI. For A.Y. 2018-19, the appellant filed its return of income declaring total income of Rs. 70,33,180/-.

2. The Ld. AO rejected the books of the assessee merely on the basis that assessee has provided some incomplete details and there were some remarks of the auditor in Form 3CD.

4. In first appeal, the Ld. CIT(A) dismissed the appeal vide order dated 24.03.2025, mainly holding that the assessee did not file effective submissions during appellate proceedings, and upheld AO’s order. Submissions:  It is humbly submitted that the Assessing Officer was not in dispute with the method of accounting followed by the assessee or compliance with the accounting standards prescribed under the Income-tax Act. The only dispute, which made him invoke Section 145(3) was the assumption that the assessee's accounts were incomplete and incorrect due to non-availability of some details and auditor’s remarks in the Form 3CD.

 The undisputed fact is that the assessee is a Private Limited Company which has been consistently following a particular method of accounting. Its accounts are audited both under the Companies Act as well as under Section 44AB of the Income-tax Act for more than 5 years.

 Auditor’s remarks in Form 3CD were general in nature (stock register, valuation, TDS reconciliation) and did not indicate unreliability of accounts.The Statutory Auditor has given unmodified opined in the Audit reportfor the same year that Financial Statement of the assessee give a true and fair view in conformity with the accounting principles generally accepted in India (PB 169).

 Ld. AO and Ld. CIT(A) failed to point out any specific instance of suppression of turnover or inflation of expenses.Uniforms and tailoring expenses were incurred for supervisory staff working at construction sites. Fuel is used for tractors and other construction equipment. Mere booking of such business expenses under ‘purchase’ does not make it unreliable.

 Assessee has submitted statement of accounts of major suppliers/vendors i.e. assessee’s account in the books of vendors (PB 213-224) to justify the purchases but the Ld. AO has failed to consider the same. Judicial Precedents:  Vishal Infrastructure Ltd. v. ACIT (2007)104ITD537(Hyd.) - ITAT Hyderabad It was held that, “5.2 In our considered opinion….the revenue has erred in rejecting its books of account and completing the assessment making huge additions. It also distinguished the case law relied upon by the revenue. We accept the contentions of the assessee especially when the Assessing Officer did not dispute the method of accounting followed by the assessee and compliance of the accounting standards prescribed under the IT Act.”

 RadhasoamiSatsang v. CIT [1992] 193 ITR 3211 (SC) The Hon'ble Supreme Court declared that though the principles of res judicata do not apply to income-tax proceedings each assessment year being a unit by itself, yet in cases, when a fundamental aspect permeating through the different assessment years has been found as a fact one way or the other and parties have been allowed that position to be sustained by not challenging the order, it may not be appropriate to allow that position to be changed in a subsequent year.

 CIT v. A.R.J. Security Printer and CIT v. Neo Poly Pack (P.) Ltd. [2000] 245 ITR 4922 (Delhi) The Delhi High Courtheld that even when the doctrine of res judicata does not apply to income-tax proceedings, where an issue has been decided consistently in a particular manner for earlier assessment years, the same view should prevail, even during the subsequent years unless there is a material change in the facts. The law is, therefore, fairly well-settled. For rejecting the view taken for the earlier assessment years, there must be a material change in the fact situation. There is no gainsaying that the previous view will have no application even in cases where the law itself has undergone a change but before an earlier view can be upset or digressed from, one of the two must be demonstrated, namely, a change in the fact situation or a material change in law whether enacted or declared by the Supreme Court. Ground No. 2 The Ld. CIT(A) has erred in confirming the estimation of income @ 8% of turnover and consequent addition of ₹91,05,708/-, which is excessive, arbitrary and not based on any comparable cases or industry practice.  Estimation at 8% was arbitrary, with no comparable case cited.  Declared NP margin (~4%) is reasonable considering the business model and government contracts.  Addition of ₹91,05,708/- is excessive and disproportionate. Ground no. 3 The Ld. CIT(A) has erred in law and on facts in holding that adequate opportunity of hearing was given, whereas the show cause notice dated 19.04.2021 allowed only 7 days during the peak of COVID-19 pandemic, and the adjournment request dated 26.04.2021 was not considered.  SCN dated 19.04.2021 allowed only 7 days to respond during the peak COVID-19 wave.  Adjournment request dated 26.04.2021 (PB 18) was ignored and order passed on 28.04.2021.  Denial of adequate opportunity vitiates the assessment proceedings.

& 1115/JPR/2025 Govindam Brj Projects Pvt. Ltd., Jaipur. Prayer In view of the above submissions and judicial precedents, it is respectfully prayed that:  The books of accounts and returned income declared by the appellantbe accepted and estimation of income @ 8% be deleted.  Consequential interest and penalty proceedings be dropped.  Any other relief as the Hon’ble bench may deem fit.”

Now we adjudicate the grounds taken by the assessee as under :

Ground Nos. 1 to 5 are inter-connected and relate to rejection of books of account under section 145(3) and making addition of Rs. 91,05,708/- @ 8% of turnover without considering the nature of infrastructure and road construction business.

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