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Case Law Details

Case Name : Charanjit Singh Vs ACIT (ITAT Chandigarh)
Appeal Number : ITA No. 337/Chd/ 2019
Date of Judgement/Order : 13/03/2024
Related Assessment Year : 2011-12
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Charanjit Singh Vs ACIT (ITAT Chandigarh)

ITAT upheld disallowance of the claimed expenditure, concluding that mere entries in books of account and inadequate invoices were insufficient to substantiate expenditure on property improvement.

In the case of Charanjit Singh Vs ACIT, the appellant appealed against the order of the Ld. CIT(A), Patiala dated 21/01/2019 for the Assessment Year 2011-12. The primary issue raised by the appellant pertained to the disallowance of a claim for expenditure incurred on the improvement of property amounting to Rs. 9 lakhs.

During the assessment proceedings, the Assessing Officer (AO) noted that while the appellant declared capital gains of Rs. 2,16,45,122, they also claimed an expense of Rs. 9 lakhs towards the cost of property improvement. The AO requested evidence to substantiate this claim, but the vouchers provided by the appellant were considered self-made and lacked evidence of improvement or tax deduction at source on payments made.

The appellant contended that the property improvement was carried out by a local contractor at a pre-agreed rate, and payments were made only after verification, duly recorded in their books. However, the AO remained unconvinced, asserting that the appellant failed to deduct tax at source against these payments and provided no clear evidence of improvement or proper invoices.

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