Challenge against Genuineness of Transaction not raised before ITAT does not survive before HC: Karnataka HC

The Karnataka High Court ruled that a challenge against the genuineness of a transaction not raised before the Income Tax Appellate Tribunal (ITAT) does not survive before the High Court. The case involved a taxpayer who did not contest the transaction’s authenticity at the ITAT level but raised the issue before the High Court. The court held that such challenges must be addressed at the ITAT stage, emphasizing the importance of procedural compliance in tax litigation.