Mr. Atul Hirji Maru Vs ACIT (ITAT Mumbai)
In a recent decision, the Income Tax Appellate Tribunal (ITAT) in Mumbai addressed two appeals from Atul Hirji Maru regarding tax assessments for the assessment years (AY) 2018-19 and 2020-21. The appeals, numbered I.T.A. No. 2879/Mum/2024 and I.T.A. No. 4064/Mum/2024, were filed against separate orders from the National Faceless Assessment Centre (NFAC), Delhi, dated 3rd May 2024 and 8th July 2024.
Background of the Case
The core issues in both appeals stemmed from the assessment of Maru’s income and deductions. The first appeal concerned a disallowance of interest amounting to ₹63,48,487. The assessing officer (AO) argued that Maru had earned this interest from his own funds and hence was not entitled to a deduction on the interest paid amounting to ₹2,02,76,955.
Additionally, the second grievance involved the treatment of maturity profits from Keyman Insurance Policies, which the AO categorized as profit in lieu of salary.
Appeal Details
The ITAT commenced by examining the appeal for AY 2018-19 (I.T.A. No. 2879/Mum/2024). Maru’s tax return had been selected for limited scrutiny under the E-assessment scheme, focusing on deductions claimed against income from various sources. The AO identified that Maru had a diversified income stream, including salary, partnership income, and income from other sources.
