SADAFULI FINVEST PRIVATE LIMITED,MUMBAI vs. THE ACIT, VAPI CIRCLE, VAPI

ITA 1332/SRT/2025Status: DisposedITAT Surat27 July 2026AY 2009-108 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that a revised return is required to claim additional TDS credit and that disallowances under Section 14A cannot be rectified under Section 154 if there is no mistake apparent from the record. Therefore, the CIT(A)'s order was upheld.

What were the facts?

The assessee sought rectification for disallowance under Section 14A and short credit of TDS. The Assessing Officer rejected the rectification application, stating that a revised return was necessary for TDS credit and that Section 14A disallowances were not rectifiable under Section 154. The CIT(A) upheld the AO's decision.

What were the issues?

Whether a revised return is mandatory for claiming TDS credit and if disallowances under Section 14A are rectifiable under Section 154.

Which sections of the Income-tax Act were involved?

Section 14A,Section 154,Section 244A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: Shri T. R. Senthil Kumar & Shri Ratnesh Nandan Sahay&

For Appellant: Shri Kirit Kamdar, C.A
For Respondent: Ms. Neerja Sharma, Sr.DR
Hearing: 04/05/2026Pronounced: 27/07/2026

PER: RATNESH NANDAN SAHAY, AM:

1.

These are the appeals filed by the assessee against the separate orders of the ld. Addl/JCIT(A)-4, Mumbai [In short, ‘the ld. CIT(A)’] both dated 31/10/2025 for the assessment year (AY) 2009-10 and 2010-11. Both the appeals have common facts and grounds, therefore, both appeals were clubbed and heard together and being decided by this common order. In ITA No. 1332/Srt/2025 Sadafuli Finvest P Ltd. Vs ACIT for the A.Y. 2009-10, the assessee has raised following grounds of appeal:

"

1.

EXCESS DISALLOWANCE OF RS. 1,68,000 UNDER SECTION 14A OF THE ACT

1.

1 On the facts and the circumstances of the case and in law, the Ld. CIT

The order continues below.

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