Allavuddin Unmarasab Hurakadli Vs National Faceless Assessment Centre (ITAT Panaji)
The Income Tax Appellate Tribunal (ITAT), Panaji Bench, delivered a split ruling in the appeal filed by Allavuddin Unmarasab Hurakadli against the order of the National Faceless Assessment Centre (NFAC) for the Assessment Year 2016-17. The appeal contested two key additions made by the Assessing Officer (AO): a disallowance under Section 69C for unexplained expenditure, and the denial of a deduction under Section 80C for housing loan repayment.
Disallowance : Remand for Verification
Regarding the first issue, the AO had made an addition of Rs. 4,81,109 under Section 69C (unexplained expenditure). The AO believed the repayment of a housing loan was made from undisclosed sources because the details were not adequately reflected in the assessee’s statement of affairs. The assessee’s counsel argued that the repayment was financed through revenue from sales and savings, supported by ledger accounts and bank statements showing transfers from the assessee’s pigmy deposit account with the credit society.
The ITAT noted that these critical evidences had not been properly examined by the lower authorities. To ensure fairness and a complete factual assessment, the Tribunal restored the issue back to the file of the Assessing Officer for de novo adjudication. The AO was directed to verify the submitted evidence and decide the matter afresh, and the assessee was instructed to fully cooperate. This ground of appeal was thus allowed for statistical purposes.
