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Case Law Details

Case Name : Bhagyashree Manohar Vs ITO (ITAT Mumbai)
Appeal Number : ITA No. 791/Mum/2023
Date of Judgement/Order : 23/05/2023
Related Assessment Year : 2011-12
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Bhagyashree Manohar Vs ITO (ITAT Mumbai)

The case sheds light on the legal framework for assessing income arising from sponsorship contributions and provides a roadmap for understanding the implications of additional evidence on tax adjudication.

Analysis

The appeal by the assessee, Bhagyashree Manohar, was set against the order of the Commissioner of Income-tax (Appeals)-National Faceless Appeal Centre, Delhi, for the Assessment Year 2011-12. Manohar, a mountaineer, received sponsorship contributions from various organizations, friends, and relatives during the Financial Year 2010-11. The Assessing Officer (AO) believed that income escaped assessment and hence issued notice under section 148 of the Act.

The central dispute revolved around the addition of Rs. 25,48,198/- without appropriate evidence of the sources of cash deposits and sponsorship contributions, leading to the AO’s dissatisfaction with the explanations provided. Manohar appealed the AO’s decision, submitting new evidence under Rule 29 of the Income Tax Rules, 1962, leading the ITAT Mumbai to rule in her favor.

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