ITO Vs Secure 1 Services Pvt. Ltd. (ITAT Amritsar)
The appeal before the Income Tax Appellate Tribunal (ITAT), Amritsar, was filed by the Revenue against the order of the Commissioner of Income Tax (Appeals) [CIT(A)] dated 07.02.2025, arising from reassessment proceedings conducted under Sections 147 read with 144 of the Income-tax Act, 1961.
The assessee company was engaged in providing security services and had not filed a return of income. Based on information available in the ITBA module and Form 26AS, the Assessing Officer (AO) noted that the company had received substantial amounts as contract receipts, supported by TDS deductions under Section 194C. Consequently, reassessment proceedings were initiated under Section 148 on 31.03.2021.
During assessment, the assessee failed to respond to multiple notices issued by the AO. In the absence of compliance, the AO completed the assessment ex parte and treated the entire gross receipts of ₹5.28 crore as taxable income.
In appeal, the assessee submitted financial documents including balance sheet, profit and loss account, bank statements, and Form 26AS. The assessee contended that it had disclosed total business receipts of ₹6.40 crore and argued that only the profit element embedded in such receipts should be taxed, rather than the gross receipts.
