TaxTMI 
TaxTMI 
2026 (6) TMI 227
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....ome Tax Act, 1961 (hereinafter referred to as the "Act") and relates to Assessment Year (A.Y.) 2022-23. 2. Grounds No.1 raised by the assessee reads as under: "1. The Ld. CIT(A) erred in law as well as on fact in upholding an addition of Rs. 3,21,675 /- made by Ld. AD on account of lower withdrawal by Incorrect analysis of earlier years data and ignoring explanation and facts submitted to clarify the same." 3. The issue involved in the above ground relates to addition made to the income of Rs. 3,21,675/- on account of low household withdrawal. 4. Briefly stated, the AO noted the assessee to have declared withdrawal of Rs. 98,935/- during the year for household expenses as compared to the drawings for immediately preceding ....
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.... of only Rs. 98,325/- for household purposes in the impugned year as opposed to Rs. 4,43,507/- in the immediately preceding year. The assessee's contention that household expenses were made by his spouse had been noted by the authorities below to have not been substantiated with documentary evidence by way of evidences being filed of expenses by spouse. The above facts have remained uncontroverted before us. In the light of the same, the fact remains that the assessee has shown unreasonably low household withdrawals as compared to the preceding year and has given no cogent reasons for the same also. He has also not furnished any evidence of household expenses having been incurred by his spouse. We, therefore, confirm the order of the Ld. CI....
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....d made addition of the outstanding balance noting that the assessee failed to submit any confirmation from the sundry creditors, their copies of ITR, and that the assessee did not submit the details of copies and bills in support of purchases made. The Ld. CIT(A) confirmed the order of the AO holding that the assessee had failed to establish identity, creditworthiness and genuineness of the transaction and that mere filing of ledger accounts was insufficient in discharge of the onus case on the assessee. 11. We are not in agreement with the findings of the authorities below. The case of the Revenue, we have noted, is that the assessee had failed to discharge its onus of proving the genuineness of the credits invoking the provisions of Se....
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....lowance of transportation/freight expense @ 30% Rs. 1,47,605/- made by Ld. AO u/s. 40(a)(ia) of the Act." 14. The issue involved in the above ground relates to addition made to the income of the assessee on account of non-deduction of tax at source on expenses incurred by the assessee by way of transportation/freight expenses u/s. 40(a)(ia) of the Act. The disallowance being made @30% of the expenses so incurred without TDS resulting in a disallowance of Rs. 1,47,605/-. 15. The facts relating to the case are that the assessee was found to have made payment to the following transporters in excess of Rs. 35,000/- without deducting tax at source: S. No Description Amount paid in rupees 1 Chudesara irfanbhai Kalubhai 1,9....