Proactive In & Out Advertising Pvt. Ltd. Vs CIT(A)-26, New Delhi
Parties Involved
Facts Summary
The case involves an appeal by Proactive In & Out Advertising Pvt. Ltd. against the order of CIT(A)-26, New Delhi dated 08.01.2025, under section 143(3) of the Income Tax Act, 1961. The assessee is aggrieved by the disallowance of Rs. 18,00,000/- paid as salary to its director, Ms. Veenu Jain, under section 40A(2)(b) of the Act, which was deemed excessive or unreasonable. The Revenue supports this disallowance, claiming it was found excessive in both lower proceedings. However, the assessee has declared income of Rs. 82,96,410/- in its director’s income tax return for the assessment year 2020-21, which is assessable at the maximum marginal rate.…
Decision in favour of
Partly Assessee / Partly Revenue
Legal Issues
- 1. Whether the disallowance of Rs. 18,00,000/- paid as salary to the director under section 40A(2)(b) is maintainable.
Judgment Outcome
Decided in favour of Partly Assessee / Partly Revenue.
Precedents Relied Upon
4 precedents cited in this judgement.
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