DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 2(3), MUMBAI vs. F A CONSTRUCTION, MUMBAI

ITA 3895/MUM/2025Status: DisposedITAT Mumbai23 January 2026AY 2014-1518 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision to delete the disallowance of expenses. It found that the disallowance was ad hoc and not supported by specific defects or cogent material, especially after the assessee provided complete documentation during appellate proceedings which was examined by the AO without adverse comments.

What were the facts?

The Revenue appealed against the deletion of additions made under Section 69A and disallowances of expenses by the CIT(A). The assessee, engaged in construction, had made substantial cash withdrawals and claimed significant expenses, but failed to provide complete substantiation during the assessment.

What were the issues?

Whether the CIT(A) was justified in deleting the addition made under Section 69A for unexplained cash withdrawals and the disallowance of expenses made on an ad hoc basis without proper substantiation.

Which sections of the Income-tax Act were involved?

Section 69A,Section 40A(3),Section 143(3),Section 147,Section 148,Section 144

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Cases cited in this judgment(1)Show list

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  • 176 Taxmann.com 270
    176 Taxmann.com 270 · 2009 · HC
    3 citing

Income Tax Appellate Tribunal, MUMBAI BENCH “F” MUMBAI

Before: SHRI SANDEEP GOSAIN & SHRI OM PRAKASH KANT

For Appellant: Mr. Vijay Mehta, Mr. Vivek A. Perampurna, CIT-DR &, Ms. Kavitha Kaushik, Sr. DR
For Respondent: Mr. Vijay Mehta, Mr. Vivek A. Perampurna, CIT-DR &, Ms. Kavitha Kaushik, Sr. DR
Hearing: 20/11/2025Pronounced: 23/01/2026

PER OM PRAKASH KANT, AM These three appeals by the Revenue are directed against three separate orders, all dated 31.03.2025, passed by the Ld. Commissioner of Income-tax (Appeals) – 48, Mumbai [in short ‘the Ld. CIT(A)'] for assessment years 2014-15 to 2016-17 respectively.

2.

As common issue in dispute is involved in these appeals and therefore, same were heard together and disposed off by way of this consolidated order for the sake of convenience.

2.

1 Now, we take up the appeal of the Revenue for assessment year 2014-15. The grounds raised by the Revenue are reproduced

The order continues below.

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