Various Appeals Filed by Aditya Birla Sun Life on Addition, Deduction and Disallowance Allowed: ITAT [Read Order]

The Income Tax Appellate Tribunal (ITAT), Mumbai Bench, heard various appeals for Assessment Year(s) [AY] 2017-18, 2018-19, 2022-23, 2023-24 on issues such as addition, deductions and disallowance and allowed them.

The Commissioner of Income Tax (Appeals) [CIT(A)] upheld the assessments of the Assessing Officer (AO) with regards to the disallowance of employees’ contribution to provident fund, disallowance of claim of interest on delayed payment of Tax Deducted at Source (TDS) and non-granting of deduction claimed under Section 80G among other grounds, in the mentioned Assessment Year(s).

For Assessment Year 2018-19, AO had computed gross total income chargeable to tax which the CIT(A) concurred with. However, the assessee, Aditya Birla Sun Life, through its counsel, claimed that it was incorrect and therefore bad in law.

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The assessee-appellant referred to the return of income (ROI) filed for Assessment Year 2023-24 and argued for the grant of total credit of TDS. In the same year, they claimed that the AO had erred and charged excess levy of interest under Section 234C of the Income Tax Act, 1961 (the Act). The Departmental representative relied on the orders passed by the CIT.

The disallowance of employees’ contribution to provident fund (PF) and of interest on delayed payment of TDS was upheld by the ITAT but granted deduction under Section 80G and allowed leave encashment for AY 2017-18. For AY 2018-19, the tribunal added deduction under Section 80G and allowed TDS under Section 40(a).

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Further, for AY 2022-23, the Tribunal deleted the disallowance under Section 36(1)(va). For AY 2023-24, Tribunal remanded the matter relating to Short Term Capital Gains back to the AO for reassessment.

The two-member bench of Amit Shukla (Judicial Member) and Makarand Vasant Mahadeokar (Accountant Member) partly allowed the appeal for issues from AY 2017-18 and 2018-19, allowed for issues from AY 2022-23 and allowed for statistical purposes or remanded the matters from AY 2023-24.

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