JEETEN JAYSHUKHLAL MEHTA,MUMBAI vs. DCIT 27(1), NAVI MUMBAI

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ITA 2997/MUM/2026Status: DisposedITAT Mumbai27 August 2026AY 2023-245 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal allowed the appeal regarding the addition under Section 69A, finding that the AO had misappreciated facts and the discrepancies were reconciled. However, the Tribunal dismissed the appeal concerning the disallowance of travelling expenses, as the assessee failed to demonstrate their business connection.

What were the facts?

The assessee challenged an addition of Rs. 27,39,649/- made under Section 69A for unexplained money and a disallowance of Rs. 4,45,803/- for travelling expenses. The addition was related to discrepancies in payments made to certain parties, while the disallowance was for travel expenses of individuals not clearly linked to the assessee's business.

What were the issues?

Whether the addition of unexplained money under Section 69A was justified, and whether the disallowance of travelling expenses for lack of business connection was correct.

Which sections of the Income-tax Act were involved?

Section 69A,Section 40(a)(ia),Section 142(1),Section 143(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “F” BENCH, MUMBAI

Before: SHRI SAKTIJIT DEY & SHRI MAKARAND VASANT MAHADEOKAR

For Appellant: Shri Siddharth Pareek
For Respondent: Ms. Meenu Ola, Sr. DR
Hearing: 18.08.2026

per the information available with the department, the purchases were to the tune of

Rs.26,39,034/-. He further observed that on perusal of the ledger account submitted by Zim

Integrated Shipping Services (I) Ltd., it was found that the assessee had paid an amount of

Rs.1,19,04,219/-. Thus, he proposed to add the differential amount to the income of the

assesse, through a show cause notice issued to the assessee. In response to the show cause

notice, the assessee again furnished a detailed reply stating that the actual payment made

was to the tune of Rs.106,52,328/-, as against the amount of Rs.1,19,04,219/- alleged to

have been paid by the assessee. Referring to the bank statement of Zim Integrated Shipping

Services (I) Ltd., the A.O. observed that the assessee had paid an amount of Rs.5,87,744/-

which is not recorded in the books of accounts of the assesse. Accordingly, he treated the

said amount as unexplained money u/s.69A of the Act.

3 ITA No. 2997/Mum/2026 (A.Y.2023-24) Jeeten Jayshukhlal Mehta vs. DCIT 5. Proceeding further, he observed that as per assessee’s books an amount of

Rs.2,36,61,980/- was paid to Star Shipping Services India P. Ltd. Whereas, as per

information available with the department, an amount of Rs.3,02,06,697/- was appearing

in parties account. Thus, according to the A.O. there was different of Rs.65,47,717/-. To

reconcile the difference, the assessee furnished a detailed reply stating that Star Shipping

Services India P. Ltd. had erroneously shown certain payments in the name of the assessee

twice which was subsequently reversed. The A.O., however, did not find merit in the

submissions of the assessee. Ultimately, he proceeded to add the amount of Rs.27,39,649/-

, being the difference in the payments made to the concerned parties. Though the assessee

contested the addition before learned first appellate authority, however, it was confirmed.

5.

We have considered rival submissions and perused the materials available on

record. Insofar as, the alleged payment of Rs.5,87,744/- to Zim Integrated Shipping

Services (I) Ltd. is concerned, the entries in the books of account clearly demonstrate that

it was received from VOYAGE India P. Ltd., a company and not VOYAGE India as

alleged by the A.O.

6.

Before us, the assessee has submitted that VOYAGE India is a proprietary concern

of the assesse, whereas VOYAGE India P. Ltd. is a company. Thus, clearly, the A.O. has

made the addition on misappreciation of facts. Therefore, the addition made of

Rs.5,87,744/- is unsustainable. Insofar as, the balance amount of Rs.21,51,905/- allegedly

paid to Star Shipping Services India P. Ltd., perusal of the bank statement of the assessee,

ledger copy of Star Shipping Services India P. Ltd. in assessee’s book and assessee’s ledger

copy in Star Shipping Services India P. Ltd. book clearly demonstrates that the assessee

had only paid amount of Rs.20,70,819.18. Except this amount, no other payment is

4 ITA No. 2997/Mum/2026 (A.Y.2023-24) Jeeten Jayshukhlal Mehta vs. DCIT reflected in assessee’s bank account or in the ledger copy of Star Shipping Services India

P. Ltd. The confusion, in our view, regarding the difference has arisen on account of

erroneous entries made in assessee’s ledger copy in the books of Star Shipping Services

India P. Ltd. On perusal of the said ledger account, placed in the paper book, it is noticed

that the amount was erroneously entered twice, which was subsequently reversed. The

subsequent reversal entry has not been considered by the departmental authorities. Thus,

in our view, the so called difference in the payment figure stands reconciled by the assessee.

Hence, there is no case for addition. Accordingly, we direct the A.O. to delete the addition

of Rs.27,39,649/-. This ground is allowed.

7.

In ground no. 2, the assessee has contested the disallowance of travelling expenses

of Rs.4,45,803/-.

8.

Briefly stated, in course of assessment proceeding, the A.O. on verification of the

details of travelling expenses noticed that the expenses were on account of travel

undertaken by various individuals. He, therefore, called upon the assessee to demonstrate

how such expenses were in connection with or for the purpose of assessee’s business.

Though the assessee emphasized that the expenses were incurred for the purpose of

assessee’s business, however, the A.O. remained unconvinced. Accordingly, he disallowed

the amount of Rs.4,45,803/-. The said disallowance was also confirmed by learned first

appellate authority.

9.

Having considered rival submissions and perused the materials on record, we find

that the amount in dispute represents travel expenses of various individuals. Neither before

the departmental authorities nor before us the assessee has been able to demonstrate in

5 ITA No. 2997/Mum/2026 (A.Y.2023-24) Jeeten Jayshukhlal Mehta vs. DCIT what capacity and manner the concerned individuals are connected with assessee’s

business and by incurring such expenses how assessee’s business has benefited.

Unfortunately, the assessee has not been able to furnish any reasonable explanation or

supporting evidences to demonstrate that the travel expenses were incurred for the purpose

of assessee’s business. In view of the aforesaid, we concur with the decision of the

departmental authorities to disallow the expenses. This ground is dismissed.

10.

In the result, the appeal is partly allowed.

Order pronounced in the open court on 27.08.2026

Sd/- Sd/-

(Makarand V. Mahadeokar) (Saktijit Dey) Accountant Member Vice President Mumbai; Dated : 27.08.2026 Roshani, Sr. PS

Copy of the Order forwarded to : 1. The Appellant 2. The Respondent 3. The CIT(A) 4. CIT - concerned 5. DR, ITAT, Mumbai 6. Guard File BY ORDER,

(Dy./Asstt. Registrar) ITAT, Mumbai

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