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Facts
The assessee, engaged in manufacturing and trading of marble and stones, filed its return declaring a certain income. The return was selected for scrutiny, and during the assessment, the Assessing Officer asked for party-wise details of purchases and expenses. The assessee failed to provide complete details, leading the AO to disallow Rs. 50 lakhs as an ad-hoc disallowance.
Held
The Tribunal held that the assessee had furnished various details in response to notices, and the Revenue's contention that no details were filed was incorrect. The Tribunal found that the CIT(A) erred in upholding the ad-hoc disallowance without establishing specific deficiencies. Therefore, the order of the CIT(A) was set aside, and the AO was directed to delete the disallowance.
Key Issues
Whether the ad-hoc disallowance of Rs. 50 lakhs made by the AO and upheld by the CIT(A) was justified when the assessee claimed to have provided sufficient details and evidence for purchases and expenses.
Sections Cited
143(2), 142(1), 133(6), 131, 40A(2)(b), 37(1), 270A
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Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE
Before: SHRI R. K. PANDA & Ms. ASTHA CHANDRA
आदेश की प्रतितिति अग्रेतिि/Copy of the Order is forwarded to:
1. 1. अपील र्थी / The Appellant; प्रत्यर्थी / The Respondent 2.