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Income Tax Appellate Tribunal, DELHI BENCH ‘A’ : NEW DELHI
Before: SH. M. BALAGANESH & SH.ANUBHAV SHARMA
The appeal has been preferred by the Assessee against the order dated 26.11.2019 of CIT(A)-22, New Delhi (hereinafter referred as Ld. First Appellate Authority or in short Ld. ‘FAA’) in appeal no. 185/19-20/CIT(A)-22, New Delhi arising out of an appeal before it against the order dated 19.12.2018 passed u/s 143(3) of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) by the ACIT, Circle-2(1), Delhi (hereinafter referred as the Ld. AO).
Heard and perused the record.
When the case was called for hearing none has appeared for the assessee. The notice issued earlier were received back unserved with reports of ‘assessee has left address’ and the department has filed a report of service of the notices. On hearing the Ld. DR, he has supported the findings of Ld. Tax authorities below.
It can be appreciated from the matter on record that the ground arises out of the fact of disallowance of Rs. 18,81,584/- as per 26AS for the difference between gross receipts as per 26AS and the sales in the P & L Account. The assessee had accepted the difference and has taken a plea that the client had reported higher amount on the basis of their internal provisions. The matter on record show that no material whatsoever in the form of evidence was filed by the assessee in support of the submission which was completely factual and required reconciliation and confirmation from the client. There is substance in the findings of Ld. AO that when assessee company is not recognizing corresponding income then it should not have claimed the credits for TDS in its return of income.
In the light of aforesaid discussion, the findings of Ld. Tax Authorities below require no interference. The grounds raised have no substance. The appeal of assessee is dismissed.
Order pronounced in the open court on 31st July, 2023.