Jakhad Enterprise LLP Vs ITO (ITAT Mumbai)
The Income Tax Appellate Tribunal (ITAT), Mumbai, addressed the appeal filed by the assessee, Jakhad Enterprise LLP, challenging the order of the Commissioner of Income Tax (Appeals) [CIT(A)] for the Assessment Year (A.Y.) 2023-24.
I. Background and Addition The assessee filed its return of income on September 30, 2023, declaring a total income of ₹3,40,91,610/-. The case was selected for scrutiny on the issue of substantial business purchases for which no Tax Deducted at Source (TDS) was deducted under Section 194Q of the Income Tax Act.
The Assessing Officer (AO) determined the total income at ₹23,67,10,338/- in the assessment order dated January 21, 2025. This was primarily done by making an addition/disallowance of ₹18,76,18,728/- under Section 40(a)(ia) of the Act. This disallowance, which represents 30% of the total business purchases of ₹62,53,95,763/-, was made on the grounds that the assessee failed to furnish details and did not deduct TDS as required by Section 194Q.
The assessee appealed the assessment order to the First Appellate Authority (CIT(A)). However, the CIT(A), via an ex parte order dated July 30, 2025, upheld the entire disallowance, noting the assessee was non-compliant and failed to respond to hearing notices.
