In the case of Raj Auto Wheels (P) Ltd vs ACIT, ITAT Jaipur meticulously analyzed additions based on customer advances and sales deferment, emphasizing legal principles and fair assessment. Tribunal’s rulings underscore the importance of genuine transactions and consistent legal application in tax assessments.
The issue involved the contention that disallowance under Section 40(a)(ia) should not be made if the payee has already paid taxes. Noteworthy payees included public limited companies such as Maruti Udhyog Ltd., and Non-Banking Finance Corporations like Sundaram Finance, AU Finance, and Mahindra & Mahindra Finance.
Tribunal concluded that the enhancement of the sale amount and the application of a higher GP rate of 3.25% lacked justification. The resultant addition of Rs. 2,26,41,521/- was deleted. However, to cover possible income leakage, an ad hoc addition of Rs. 2,00,000/- was allowed.
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Assessee had shown sufficient cause for the delay in filing the appeals before the Tribunal as he was old and not well acquainted and conversant with the digital system in order to follow up with the income tax notices, which were posted in IT portal. Accordingly, the delay in filing appeal was condoned.