MSN LIFE SCIENCES PRIVATE LIMITED,HYDERABAD vs. ACIT., CENTRAL CIRCLE-2(4), HYDERABAD

ITA 1072/HYD/2024Status: DisposedITAT Hyderabad04 February 2025AY 2020-2158 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal directed the Assessing Officer to allow 60% of the receipts as expenditure against unaccounted cash receipts from the sale of spent solvents/scrap, sustaining 40% of the addition. The Tribunal also upheld the validity of the Assessing Officer's jurisdiction under Section 153A.

What were the facts?

During a search operation, unaccounted cash receipts from the sale of spent solvents and scrap were discovered. The assessee claimed deductions for expenses incurred against these receipts, which were partly allowed by the CIT(A). The validity of the Assessing Officer's jurisdiction under Section 153A was also challenged.

What were the issues?

Whether the assessee is entitled to a deduction for expenses against unaccounted income from sale of spent solvents/scrap, and whether the Assessing Officer validly assumed jurisdiction under Section 153A for assessment years beyond six years preceding the search.

Which sections of the Income-tax Act were involved?

Section 153A,Section 132,Section 2(22)(e)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, HYDERABAD BENCHES “A”, HYDERABAD

Before: SHRI LALIET KUMAR, HON’BLE & SHRI G. MANJUNATHA, HON’BLE

For Appellant: Shri M.V. Prasad, C.A, Shri K.S. Rajendra Kumar
For Respondent: Shri B. Bala Krishna, CIT-DR
Hearing: 23.12.2024Pronounced: 04.02.2025

PER BENCH : The appeals of the assessee for A.Ys.2013-14, 2014-15, 2019-20 and 2020-21 arise from the separate orders of Commissioner of Income Tax (Appeals) 12, dated 22.08.2024, dt.27.09.2014 dt.13.09.2024 and dt.19.08.2024, respectively. The Revenue filed cross appeal for A.Y. 2020-21 only. Since, the facts are identical and issues ar

The order continues below.

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