INBOX PICTURES PRIVATE LIMITED,MUMBAI vs. DCIT, CIRCLE-16 (1), MUMBAI

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ITA 3774/MUM/2025Status: DisposedITAT Mumbai30 October 2025AY 2017-18Bench: BEFORESHRI OM PRAKASH KANT (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)1 pages

In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal noted that the assessee failed to provide documentary evidence for claimed expenses and could not satisfactorily explain the source of cash deposits. Despite opportunities, the assessee was absent during the hearing and failed to produce credible material to rebut the revenue authorities' findings.

What were the facts?

The assessee, engaged in film production and distribution, filed its return for AY 2017-18. The assessment order included additions for expenses, cash deposits during demonetization, and sundry creditors. The assessee's appeal to the CIT(A) was rejected, leading to this appeal before the Tribunal.

What were the issues?

Whether the additions made by the Assessing Officer regarding expenses, cash deposits, and sundry creditors are justified, given the assessee's failure to provide supporting evidence.

Which sections of the Income-tax Act were involved?

Section 250,Section 143(3),Section 37(1),Section 69A,Section 115BBE,Section 68,Section 46A,Section 34(4)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “C”, MUMBAI

For Respondent: Shri R.A. Dhyani, (CIT DR)
Hearing: 16/10/2025Pronounced: 30/10/2025

O R D E R Per Anikesh Banerjee, JM:

The Instant appeal of the assessee was filed against the order of the Learned Commissioner of Income-tax (Appeals)-52, Mumbai [for brevity, ‘Ld. CIT(A)’] passed under section 250 of the Income-tax Act, 1961 (in short, the Act’) for Assessment Year 2017-18, date of order 19/11/2024. The impugned order emanated from the order of the Learned Assistant Commissioner of Income-tax, Inbox Pictures Private Limited Central Circle-16(1), Mumbai (in short, he ‘Ld.AO) passed under section 143(3) of the Act, date of order 24/12/2019.

2.

When the appeal was called up for hearing, no one was present on behalf of the assessee. No adjournment petition was filed. On perusal of the record, we found the matter was fixed on 14/10/2025. On that date the Ld. AR appeared virtually and sought for adjournment. The adjournment as granted till 16/10/2025. But on 16/10/2025 none was present on behalf of the assessee. Considering the facts of the case we proceeded to dispose of the appeal exparte qua for assessee, after hearing Ld.DR.

3.

We heard the Ld.DR and considered the documents available on the record. The Ld.DR filed a note, which is kept on record. The Ld.DR stated that the assessee is engaged in business of film production, film distribution, dubbing and mixing of films. The assessee was incorporated on 11/05/2016. Accordingly, this is the first year of operation. The return was filed on 01/03/2016 by declaring total income at Rs. 60,32,150/-. Finally, the assessee’s return was selected for scrutiny and the assessment order was framed u/s 143(3) of the Act with an addition of expenses u/s 37(1) of the Act, amount to Rs.61,61,000/-, addition u/s 69A r.w.s. 115BBE of the Act amount to Rs.66,21,567/- on account of the cash deposit during the demonetization period, and sundry creditors u/s 68 r.w.s. 115BBE of the Act amount to Rs.9,46,17,147/-. The aggrieved assessee filed an appeal before the Ld.CIT(A). The Ld.CIT(A), after considering the submissions of the assessee rejected the assessee’s appeal and upheld the additions. Being aggrieved, assessee filed an appeal before us.

4.

We observe that the additions made in the assessee’s case pertain to disallowances under section 37(1) of the Act, amounting to Rs.21,01,000/- under Inbox Pictures Private Limited the head “Other Expenses” and Rs.40,60,000/- towards “Legal and Professional Fees,” aggregating to Rs.61,61,000/-. During the course of the assessment as well as the appellate proceedings, the assessee failed to furnish supporting documentary evidence to substantiate these expenditures. Consequently, the said additions were confirmed.With regard to the cash deposits made during the demonetisation period, the assessee could not satisfactorily explain the source of such deposits. Therefore, the addition made under section 69A of the Act was also confirmed. In respect of the addition relating to sundry creditors, the assessee had furnished additional evidence before the Ld. CIT(A) under Rule 46A of the Income-tax Rules, 1962. However, the Ld. CIT(A) was not convinced by the explanation offered by the assessee regarding the non-submission of such evidence before the Ld. AO.

5.

During the appellate proceedings before the Tribunal, the assessee again failed to produce any documentary evidence in support of the claims made. Despite being afforded multiple opportunities, there was no representation on behalf of the assessee at the time of hearing. In view of these facts and in the absence of any credible material to rebut the findings of the revenue authorities, we find no reason to interfere with the order of the Ld. CIT(A). Accordingly, the appeal filed by the assessee stands dismissed.

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