K.V Education Ventures Pvt. Ltd. Vs. ITO, Ward-1, Raipur

Parties Involved

Facts Summary

K.V Education Ventures Pvt. Ltd. filed an appeal against the order passed by the ADDL/JCIT(A)-1, Delhi dated 09.06.2024, which arose from the order passed by the A.O under Sec.143(3) of the Income-tax Act, 1961 dated 19.12.2019 for the assessment year 2017-18. The assessee company had e-filed its return of income for A.Y.2017-18 on 30.12.2017, declaring an income of Rs.15,39,984/-. The case was selected for scrutiny assessment u/s.143(2) of the Act. The A.O determined the income of the assessee at Rs.9,20,851/- after making the following additions/disallowances: 1. Disallowance u/s. 40(a)(ia) of the Act Rs.3,75,000/- 2. Disallowance of the assessee’s claim of deduction of expenditure (on ad-hoc basis) Rs.2,48,851/- 3. Addition on account of notional lettable value of property u/s. 24(a) of the Act Rs.2,97,000/- The assessee carried the matter in appeal before the CIT(Appeals) but without success. The assessee being aggrieved with the order of the ADDL/JCIT(A) has carried the matter in appeal before the tribunal.…

Legal Issues

• 1. Disallowance of Rs.3,75,000/- being 30 percent of Rs.12.50,000/- u/s.40(a)(ia) of the Income-tax Act, 1961.
• 2. Disallowance of Rs.2,48,851/- treating corresponding claims as capital expenditure, which in fact are revenue in nature.
• 3. Disallowance of deduction u/s.24(a) of the Income-tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

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