URMIN PRODUCTS PVT. LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(3), AHMEDABAD

ITA 1006/AHD/2023Status: DisposedITAT Ahmedabad14 June 2024AY 2018-19Bench: SHRI T.R. SENTHIL KUMAR (Judicial Member), SHRI NARENDRA PRASAD SINHA (Accountant Member)15 pages
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What did the Tribunal hold?

The Tribunal held that the AO failed to record his dissatisfaction as required by Section 14A(2) before invoking Rule 8D. Additionally, the Tribunal directed the AO to dispose of the assessee's application for recomputation of income under Section 155(18).

What were the facts?

The assessee company engaged in manufacturing chewing tobacco made suo moto disallowance for expenses related to exempt income. The Assessing Officer (AO) invoked Section 14A read with Rule 8D, making a higher disallowance. The Commissioner (Appeals) upheld the AO's order.

What were the issues?

Whether the AO properly invoked Section 14A read with Rule 8D without recording dissatisfaction, and whether the assessee's application under Section 155(18) should be considered.

Which sections of the Income-tax Act were involved?

Section 14A,Section 155(18)

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Income Tax Appellate Tribunal, “C” BENCH, AHMEDABAD

Before: SHRI T.R. SENTHIL KUMAR & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri Aseem L. Thakkar, AR
Hearing: 29/04/2024Pronounced: 14/06/2024

आदेश आदेश आदेश PER T.R. SENTHIL KUMAR, JUDICIAL MEMBER:

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These two appeals are filed by the assessee as against the appellate orders dated 17.10.2023 and 18.10.2023 passed by the Commissioner of Income-Tax (Appeals), Ahmedabad-11 (hereinafter referred to as the “CIT(A)” in short), arising out of the assessment orders passed under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as the “the Act” in short), relating to the Assessment Years (AYs) 2018-19 and 2020-21

The order continues below.

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