ITAT Mumbai Deletes ₹1.26 Cr Income Addition for Lack of Income Character

Sanjay Kothari (HUF) Vs National Faceless Assessment Centre (ITAT Mumbai) ITAT Mumbai Restricts 14A Disallowance to Actual Expenses of ₹69,455 & Deletes ₹1.26 Cr Addition Treating Excess Refund of Advance as Capital Receipt Assessee–HUF filed appeal against the NFAC order sustaining two additions: (i) ₹6,74,600 u/s 14A r.w. Rule 8D, & (ii) ₹1,26,32,970 treating excess refund of advance from its Karta (Mr. Sanjay Kothari, individual) as taxable income. 1. Section 14A / Rule 8D Disallowance – Partly Allowed The assessee earned exempt income of ₹2.34 crore but made no 14A di...