“Section 143(1)(a)(iv)”

Surana Motors Private Limited, Mumbai vs. Dy CIT, CPC, Bangalore

In the result, all the appeals are allowed in the terms indicated above

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of "disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Master Polishers Private Limited, Mumbai vs. DCIT, CPC, Mumbai

In the result, all the appeals are allowed in the terms indicated above

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of "disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Fortive India Pvt. Ltd, Mumbai vs. National Faceless Appeal Centre, Delhi

In the result, appeal filed by the Appellant is partly allowed

expenditure under the Act? As we deal with this question, we 7 Assessment Years: 2018-19 are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of "disallowance of expenditure indicated in the audit report but not taken into account in computing the total income ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Nilesh V. Metha, Mumbai vs. DCIT 32(1), Mumbai

In the result, all the appeals are allowed in the terms indicated above

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of "disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

M/S Vaishali Pharma Limited, Mumbai vs. Dy CIT CPC, Bangaluru

In the result, all the appeals are allowed in the terms indicated above

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of "disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

M/S. Mazgaon Dock Shipbuilders Ltd, Mumbai vs. Addl/Jt/Dy/ACIT, Delhi

In the result, the appeal of the assessee is allowed

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of “disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Stg Refractory Services Pvt. Ltd., Mumbai-400042 vs. Dy Commissioner of Income Tax, Central Processing Centre, Karnataka-560500

In the result, all the appeals are allowed in the terms indicated above

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of "disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Chauhan Lifters, Mumbai vs. Commissioner of Income Tax (A) NFAC, Delhi

In the result, the appeal filed by the assessee is allowed

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 1289/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2019-20) National Faceless Chauhan Lifters Appeal Centre (Nfac), 124-3, Bhaskar Niwas Road No. बिधम/ Delhi 4, Scheme No. 6, Sion East, Vs. Maharashtra-400 022 स्थायीलेखासं./जीआइआरसं./ Pan No. Aakfc2375E (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By None : प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 26.10.2021, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2019-20. 2

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of “disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

M/S S. K. International, Mumbai vs. DCIT 17(1), Mumbai

In the result, the appeal filed by the assessee is allowed

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 1251/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2019-20) Dcit-17(1), M/S. S. K. International Kautilya Bhavan, Near S. K. House, 94-A, Aval Baug, बिधम/ Videsh Bhavan, Bandra D. S. P. Road, Dadar (E), Vs. Kurla, Mumbai-400 051 Mumbai-400 014 स्थायीलेखासं./जीआइआरसं./ Pan No. Aamfs2232C (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By None : प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 22.04.2022, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2019-20. 2

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of “disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Agaskar Civil & Garden Contractors, Mumbai vs. NFAC, Delhi

In the result, the appeal filed by the assessee is allowed

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 1247/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2019-20) National Faceless Agaskar Civil & Garden Appeal Centre (Nfac), Contractors बिधम/ Delhi Plot No. A-249, Namdeo Smruti, Vs. Sector-19, Koparkhairanine, Navi Mumbai-400 709 स्थायीलेखासं./जीआइआरसं./ Pan No. Abcfa6438K (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : None प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 30.03.2022, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2019-20. 2

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of “disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Pace Setters Business Solutions Pvt. Ltd, Mumbai vs. Dy.CIT CPC Bangalore & Cir 8(2) (1), Mumbai

In the result, the appeal filed by the assessee is allowed

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 1216/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2018-19) Dcit, Cpc, Bangalore & Pace Setters Business Circle 8(2)(1), Mumbai Solutions Pvt. Ltd. बिधम/ 1 Bori Bunglow, 49 S K Bole Vs. Road, Prabhadevi, Mumbai-400 028 स्थायीलेखासं./जीआइआरसं./ Pan No. Aadcp7717M (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : Shri Bharat Kumar, Ld. Ar अपीलाथीकीओरसे/ Appellant By : प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 23.03.2022, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2018-19. 2

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of “disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Seven S Banking Management Consultancy Services (P) Ltd, Mumbai-400069 vs. Circle-11(2)(1), Mumbai-400020

In the result, the appeal filed by the assessee is allowed

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 1167/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2019-20) Circle-11(2)(1), Seven S Banking Management Mumbai Consultancy Services (P) Ltd. बिधम/ Office No. 104, Eco Heights, Shree Nityanand Society, Vs. Swami Nityanand Marg, Andheri East, Mumbai-400 069 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaecs7701B (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : None प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 26.03.2022, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2019-20. 2

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of “disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

M/S Aashis Products, Mumbai vs. DCIT, CPC, Bangaluru, Banguluru

In the result, the appeal filed by the assessee is allowed

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 1131/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2018-19) Dcit, Centralized M/S. Aashis Products बिधम/ Processing Centre, Plot No. 23, Midc, Road No. 9, Vs. Bengaluru-560500 Andheri(E), Mumbai-400 093 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaafa1695H (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : None प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 25.10.2021, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2018-19. 2. The Ground Taken Before Us Is That, Ld. First Appellate Authority Has Erred In Law & On Facts In Holding Addition U/S 2

Products enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of “disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Qualiance International Pvt. Ltd, Mumbai vs. CPC, Bangaluru

In the result, the appeal filed by the assessee is allowed

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 2357/Mum/2021 (निर्धारणवर्ा / Assessment Year: 2019-20) Centralized Processing Qualiance International Pvt. Centre, Ltd. बिधम/ Bengaluru-560500 B-406, Knox Plaza, Mind Space, Vs. Next To Tangent Showroom, Malad (W), Mumbai-400 064 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaacq1420B (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : None प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 29.10.2021, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2019-20. 2

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of “disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

M/S. Lavino Kapur Cottons Pvt. Ltd, Mumbai vs. DCIT Cir 3(2) (1), Mumbai

In the result, both the appeals filed by the assessee are allowed

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 2102 & 2103/Mum/2021 (निर्धारणवर्ा / Assessment Year: 2017-18 & 2018-19) Dcit Cir-3(2)(1), M/S Lavino Kapur Cottons Aayakar Bhavan, Pvt. Ltd. बिधम/ Maharshi Karve Road, 121/122, Mittal Chambers, Vs. Churchgate, Nariman Point, Mumbai-400 020 Mumbai-400 021 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaacl0824C (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Surinder Mehra, Ld. Ar प्रत्यथीकीओरसे/Respondent By : Shri Mehul Jain, Ld. Dr सुनवाईकीतारीख/ : 02.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeals Have Been Filed By The Assessee Against The Separate Impugned Order Of Even Date 10.09.2021, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2017-18 & 2018-19. 2

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of “disallowance of 11 I.T.A. No. 2102 & 2103/Mum/2021 M/S Lavino Kapur Cottons Pvt. Ltd expenditure indicated ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Rishabh Metals and Chemicals Pvt. Ltd., Mumbai vs. CPC, DCIT -Cir 1(3)(1), Mumbai

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhrishabh Metals & Vs. Dcit, Circle- 1(3)(1) Chemicals Pvt Ltd, Aayakar Bhavan, 4Th Floor, Eros Theater Mk Road, Bldg, J.T.Road, Mumbai-400020. Churchgate, Mumbai-400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr2214E Appellant .. Respondent Appellant By : None Respondent By : Shri Pankaj Kumar.Dr Date Of Hearing 23.06.2022 Date Of Pronouncement 27.06.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Cit(A)- National Faceless Appeal Centre (Nfac), New Delhi Passed U/S 143(1) & 250 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal.

taking into account in the computation of total income in the return” as is sine qua non for disallowance of Section 143(1)(a)(iv). When the due date under Explanation to Section 36(1)(va) is judicially held to be not decisive for determining the disallowance in the computation ... 143(3) r.w.s. 147 of the Act, or when no findings were to be given on the scope of permissible adjustments under section 143(1)(a)(iv). That is not the situation before us. We, therefore, see no need to deal with that aspect of the matter at this stage

M/S. Super Tiles & Marbles Pvt. Ltd, Mumbai vs. NFAC, New Delhi

In the result, appeals of the assessee are allowed

Bench: The Due Date Of Filing Of Income Tax Returns U/S.139(1) Of The Act, Could Be Subject Matter Of Adjustment U/S.143(1)(A) Of The Act By The Central Processing Centre (Cpc).

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of "disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Ketan Brothers Diamonds Exports, Mumbai vs. ACIT 23(2) /ACIT 23(1), Mumbai

In the result, appeal by the assessee is allowed for statistical purpose

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of “disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Swaroopsing Bhadursingh Rathore, Thane vs. Asstt.Director of Income Tax, CPC, Banglore

In the result, appeals of the assessee are allowed

Bench: The Due Date Of Filing Of Income Tax Returns U/S.139(1) Of The Act, Could Be Subject Matter Of Adjustment U/S.143(1)(A) Of The Act By The Central Processing Centre (Cpc).

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of "disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1

Swaroopsingh Bhadursingh Rathore, Thane vs. Deputy Commissioner of Income Tax - CPC, Banglore

In the result, appeals of the assessee are allowed

Bench: The Due Date Of Filing Of Income Tax Returns U/S.139(1) Of The Act, Could Be Subject Matter Of Adjustment U/S.143(1)(A) Of The Act By The Central Processing Centre (Cpc).

justifications enough for any disallowance of expenditure under the Act? As we deal with this question, we are alive to the fact section 143(1)(a)(iv) specifically an adjustment in respect of "disallowance of expenditure indicated in the audit report but not taken into account in computing the total ... contentions in this regard that the observations made in the tax audit report, in the light of the specific provisions of Section 143(1)(a)(iv), must prevail- more so when the tax auditor is appointed by the assessee himself, is clearly unsustainable in law. While Section 143(1