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Income Tax Appellate Tribunal, AGRA BENCH, “SMC” AGRA
Before: SHRI SATBEER SINGH GODARA & SHRI M. BALAGANESH
Assessment Year: 2014-15 Vs. Assessing Officer-2(2)(5), Sh. Ajay Bhatia, 117/H-2/126, Pandu Nagar, Etawah, Kanpur Uttar Pradesh PAN :ACBPB9601R (Appellant) (Respondent) Assessee by Sh. Anurag Sinha, Adv. Department by Sh. Shailender Shrivastava, Sr. DR Date of hearing 06.02.2025 Date of pronouncement 06.02.2025 ORDER
PER SATBEER SINGH GODARA, JM
This assessee’s appeal for assessment year 2014-15 arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2024-25/1064749066(1) dated 09.05.2024 involving proceedings under section 154 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
It emerges during the course of hearing that both the learned lower authorities have taken recourse to section 154 rectification for the purposes of disallowing the assessee’s revenue expenditure representing interest and remuneration payments etc. amounting to Rs.1,56,552/-; as not allowable under section 37(1) of the Act, in the Assessing Officer’s order dated 23rd of January, 2019, as upheld in the lower appellate discussion.