Case Law Analysis
|Income Tax Appellate Tribunal
Ad Hoc Disallowance of Truck Rent Expenses Without Section 133(6) Inquiry or Comparative Basis Violates Natural Justice : ITAT Ahmedabad
The ITAT Ahmedabad has struck down the arbitrary 20% disallowance of truck rent expenses, ruling that tax authorities cannot impose such adjustments without conducting a proper comparative analysis or invoking Section 133(6) to verify genuineness. This sets a critical precedent for transport businesses and SMEs facing mechanical tax adjustments, reinforcing that procedural fairness is non-negotiable even in scrutiny assessments.