ACIT,CIRCLE-2(1),RAJKOT, RAJKOT vs. HANUMAN INDUSTRIES, AMRELI

ITA 655/RJT/2025Status: DisposedITAT Rajkot21 September 2026AY 2014-1510 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision to delete the transfer pricing adjustment, finding that the transactions with Associated Enterprises were appropriately benchmarked and tax-neutral. The disallowance of interest was also deleted as no nexus between borrowed funds and interest-free advances was established. The addition on account of interest income was deleted as it was already accounted for in the books.

What were the facts?

The Revenue appealed against the deletion of transfer pricing adjustment, disallowance of interest expenditure, and addition on account of unaccounted interest income by the CIT(A). The assessee is a partnership firm engaged in trading and export of agricultural produce.

What were the issues?

Whether the CIT(A) erred in deleting the transfer pricing adjustment, disallowance of interest, and addition on account of interest income.

Which sections of the Income-tax Act were involved?

Section 250,Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “RAJKOT BENCH” , RAJKOT

Before: DR. B.R.R. KUMAR & SHRI SONJOY SARMA

For Appellant: Shri R V Aroon Prasaad, Sr.DR
For Respondent: Shri Kalpesh Doshi, AR
Hearing: 28.07.2026Pronounced: 21.09.2026

PER: DR. B.R.R. KUMAR, VICE PRESIDENT:

This appeal has been filed by the Revenue against the order of the Ld. Commissioner of Income-Tax (Appeals)-Ahmedabad-13 (hereinafter referred to as "Ld. CIT(A)" for short) dated 19.08.2025, passed u/s 250 of the Income-tax Act, 1961, (hereinafter referred to as "the Act" for short) for the Assessment Year (AY) 2014-15. ACIT vs Hanuman Industries Asst.Years : 2014-15 - 2–

2.

The Revenue has raised the following grounds of appeal:

1.

That on the facts and in the circumstances of the case, the Ld. CIT A has erred in deleting the upward adjustment of Rs. 2,49,75,211/- made by the AO on account of TP provisions.

The order continues below.

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