ITA Nos. 6685 to 6687 and 6546 & 6552/M/2025

Parties Involved

Facts Summary

The assessee, Sajjid Amir Khan, is a proprietor of M/s SAKS INDIA, engaged in exporting hand-embroidery garments. A survey under section 133A was conducted on 30.06.2018, leading to re-assessment proceedings for assessment years 2014-15 to 2016-17 and assessment proceedings for 2017-18 to 2019-20. The Commissioner of Income Tax (Appeals) [Ld. CIT (A)] passed orders for assessment years 2018-19 and 2019-20, which were based on the order for AY 2017-18. The revenue and the assessee have filed cross-appeals for assessment years 2018-19 and 2019-20.…

Legal Issues

• 1. Deletion of disallowance of Rs. 96,60,000/- towards consultancy services paid to Shri Upendra Rai.
• 2. Deletion of addition of Rs. 13,48,19,395/- made under section 68 on account of unexplained unsecured loans.
• 3. Deletion of disallowance of Rs. 1,49,68,256/- on account of sales promotion expenses.
• 4. Deletion of disallowance of Rs. 3,31,78,638/- made under section 40(a)(i) in respect of commission paid to a non-resident without deduction of tax at source.
• 5. Deletion of disallowance of Rs. 20,48,116/- out of travelling expenses.
• 6. Deletion of disallowance of Rs. 2,80,92,346/- out of labour expenses.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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