CIT(A) restricted addition on account of accommodation entries ...
Tribunal Upholds Reduced Tax Additions and Deductions, Dismisses Revenue's Claims Due to Insufficient Evidence.
November 20, 2024
Case Laws Income Tax AT
CIT(A) restricted addition on account of accommodation entries to 15% instead of 100%, as the Assessing Officer failed to establish that work was not actually performed. The Tribunal concurred with CIT(A)'s disallowance rate of 15% and rejected Revenue's contention to restore 100% disallowance. Regarding commission expenses of INR 8,81,3000/-, the Tribunal upheld CIT(A)'s deletion in the absence of material to substantiate the allegation of 1% commission payment. CIT(A) correctly allowed the claim of deduction u/s 80-IA based on the Assessing Officer's remand report. Concerning disallowance u/s 14A, the Tribunal upheld CIT(A)'s findings as the assessee had suo moto disallowed a higher amount of 1% of average investment as administrative expenses compared to the Assessing Officer's disallowance of 0.5%. The Tribunal dismissed the Revenue's grounds on all issues.
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