ITAT Patna held that in absence of any evidence of tax evasion by showing fictitious or false transactions, addition by invoking provisions of section 40A(3) of the Income Tax Act unsustainable.
So far as the disallowance made by the ld. Assessing Officer under section 40(a)(ia) of the Income Tax Act is concerned, it is noted that since the income of the assessee is exempt under section 10(23C)(vi), therefore, any disallowance made under section 40(a)(ia) by the ld. Assessing Officer will only add to the income of the assessee, which otherwise is exempt under section 10(23C) as stated above.
Shrawan Goenka Vs ACIT (ITAT Patna) Brief facts relevant to the issue are that during the assessment proceedings, the Assessing Officer noted that the assessee had debited in his Profit & Loss A/c, a sum of Rs.4,94,006/- under the head bad debts. On being asked to produce the details along with supporting papers, bills, vouchers, […]
