INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
HIRENKUMAR AMRUTLAL BORICHA INDIA – Appellant
Versus
INCOME TAX OFFICER 24(2)(1) PIRAMAL CHAMBER MUMBAI – Respondent
आदेश / ORDER
PERBEENA PILLAI, JUDICIAL MEMBER:
Present appeal filed by the assessee arises out of the final order dated 21/12/2023 for A.Y. 2013-14 on the following grounds of appeal:-
“1) General Grounds
2) Specific ground relating to addition of Rs. 10,14,681 on account of unexplained credit card expenditure by the appellant without appreciating the fact that close to 75 percent of the expenditure pertained to expenses of partnership firm Modern Plastic Industries and payment to the credit card company was directly made by the firm, for which complete banking trail is available.
3) Specific ground relating to addition of Rs. 3,24,025 as salary income without considering the deduction of TDS on such income and that the appellant ought to have granted TDS credit of Rs. 2,692 on the same.
4) Alternative ground relating to double taxation OR computation error. Since salary income was already added by the Assessing officer as part of total income, the same was available with the Appellant to make a part of the credit card expenditure. Thus, the maximum amount of addition as unexplained expenditure could be Rs. 6,90,656, being Rs. 10,14,681 less Rs. 3,24,025.”
2. Brief facts of the cas
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