Survey Admission Alone Cannot Justify Full Disallowance: ITAT Chennai Restricts Land Development Expense Disallowance to 10%

Suresh Ramachandran Vs ACIT (ITAT Chennai) The Chennai Bench of the ITAT partly allowed the assessee’s appeal for AY 2017-18 and substantially reduced the disallowance of land development expenditure made under Section 37 pursuant to survey and revision proceedings. The assessee, engaged in retail hardware business and real estate development, had during a survey under Section 133A voluntarily offered ₹65 lakh as additional income due to inability to immediately substantiate certain development expenses. Although the original reassessment disallowed only ₹7.99 lakh, the PCIT invoked Sect...