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Showing contexts for: turnover decrease in M/S Alliance Builders & Contractors ... vs Dy. Commissioner Of Income Tax, Kanpur on 20 February, 2023Matching Fragments
6. Ground no. 2 is in respect of addition of Rs.7,20,000/- on account of directors' remuneration being treated as excessive u/s. 40A(2) of the Act. In this respect, Ld. AO had made a disallowance of Rs.14,40,000/- out of which Ld. CIT(A) gave a partial relief and sustained disallowance of Rs.7,20,000/- and the assessee is in appeal before the Tribunal.
6.1. The moot point of contention by the Ld. Counsel is that authorities below have not brought out any contrary material except their own observations which are based on surmises and conjecture, to demonstrate that the remuneration paid to the directors is excessive. Ld. Counsel also referred to the book results of five years which were produced before the Ld. AO, to demonstrate that the allegation of Ld. AO that there is substantial decrease in the turnover and net profit of the company as against substantial increase in the remuneration of directors is factually incorrect. The said book results are tabulated below: