Detective And Security Services Vs DCIT (ITAT Ahmedabad)
Income Tax Appellate Tribunal (ITAT), Ahmedabad Bench, has partially allowed an appeal filed by Detective And Security Services, remanding the case back to the Assessing Officer (AO) for re-verification of a disputed income addition. The firm had challenged an order from the National Faceless Appeal Centre (NFAC), Delhi, concerning the assessment year 2015-16.
The core of the dispute revolves around an addition of Rs. 15,43,980 made by the AO. This amount represented a discrepancy identified between the receipts declared by Detective And Security Services in its audited accounts and the figures reported in Form 26AS, which details tax deducted at source.
The firm had initially filed its return declaring a total income of Rs. 97,73,900. However, the AO initiated proceedings under Section 148 of the Income Tax Act, 1961, believing there was unexplained money. Following the assessee’s reply, an assessment order under Section 147/144B was issued on May 11, 2023, assessing the total income at Rs. 1,13,17,880, incorporating the disputed addition.
Aggrieved by this assessment, Detective And Security Services appealed to the Commissioner of Income Tax (Appeals), NFAC, Delhi. The CIT(A) dismissed the appeal, asserting that the firm had not filed submissions in response to a Section 250 notice. The assessee, however, contended that submissions were indeed filed on February 28, 2025, with specific acknowledgement numbers.
