ACIT Vs Dish Infra Services Pvt. Ltd. (ITAT Delhi)
The case of ACIT vs. Dish Infra Services Pvt. Ltd. revolves around several key issues raised by the Revenue against the order of the ld. CIT(A)-3, New Delhi dated 10.08.2020. The Revenue’s appeal addresses various aspects including unexplained cash credit, debenture issue expenditure, and disallowance of interest under section 36(1)(iii) of the Income Tax Act, 1961. Let’s delve into each of these matters as discussed in the full text of the order of ITAT Delhi.
Unexplained Cash Credit: During the relevant assessment year, the assessee received deposits and advances amounting to Rs. 705.05 Cr. for various purposes such as Dish installation, EPRS recharge collection, security deposits, and advances from Dish Care center. The Assessing Officer (AO) made an addition of Rs. 1.20 Cr. under section 68 of the Act due to non-submission of PAN and confirmation from the parties. The ld. CIT(A) partly deleted the addition, confirming Rs. 26.88 lacs, while deleting the rest. The ld. CIT(A) accepted advances from certain parties who could prove the validity of the advances and confirmed the amounts received from other parties who failed to prove the advances given. The Tribunal declined to interfere with the order of the ld. CIT(A) as it was based on factual verification.
