SKF Engineering & Lubrication India Private Limited Vs ACIT (ITAT Bangalore)
Bengaluru ITAT-Manual Signature on E-Assessment Order Does Not Invalidate Assessment
The Bengaluru ITAT partly allowed the assessee’s appeal arising from an assessment under section 143(3) read with section 254, holding that the manual signature on an assessment order passed after e-proceedings does not render the order invalid, as section 282A expressly permits orders issued in paper form to be manually signed and any procedural defect is protected by section 292B. On merits, however, the Tribunal granted substantial relief by deleting multiple disallowances. It held that ₹23.03 lakh incurred on slotted-angle racks, heavy-duty racks, modules and similar items constituted revenue expenditure on repairs and maintenance, as no new asset or enduring benefit was created. The Tribunal also deleted the disallowance of ₹35.87 lakh towards consumables issued to the shop floor, observing that the Revenue had failed to appreciate the assessee’s accounting system under which materials were first purchased and later charged to the profit and loss account upon consumption. Further, it allowed the write-off of ₹6.97 lakh representing irrecoverable advances to vendors, holding that the loss arose in the ordinary course of business and was allowable as a business loss under section 28. However, it upheld the disallowance of ₹1.82 lakh contributed to the Uttarakhand Relief Fund, as the assessee failed to establish that the payment was incurred wholly and exclusively for business purposes under section 37(1), though it observed that the claim could be considered separately under section 80G, if otherwise eligible.
