Issues before the Hon’ble ITAT Amritsar Bench, Amritsar.

1.Whether revenue has power to make disallowance under section 40A(7) on a due perusal of tax audit report submitted by the auditor for the respective year under reference ?

2.Whether assessee must be given an opportunity of being heard before the revenue proceeds to sustain disallowance under section 40A(7) of the Income Tax Act, 1961 by taking tax audit report as its base ?

3.Whether disallowance made under section 143(1) by referring to the tax audit report of the auditor cannot be disturbed by taking recourse to section 154 of the Income Tax Act, 1961 ?

4.Whether AO is required to re-adjudicate the issue once assessee contends that no effective opportunity was provided before proceeding to make disallowance under section 40A(7) qua 143(1) qua 154 ?