BAGRODIA PLANTATIONS AND INDUSTRIES PVT LTD,DAYAMANI KUNJ vs. ITO WARD 1(1) DIB, AAYAKAR BHAWAN

ITA 152/GTY/2026Status: DisposedITAT Guwahati16 July 2026AY 2017-1810 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the increased business income due to the disallowance of cultivation expenses is eligible for deduction under Section 80-IE of the Income Tax Act. Therefore, the addition made by the AO should be deleted.

What were the facts?

The assessee claimed cultivation expenses for tea manufacturing. The Assessing Officer (AO) disallowed 82.49% of these expenses, attributing them to bought tea leaves rather than self-grown ones. The CIT(A) confirmed this addition.

What were the issues?

Whether cultivation expenses are allowable for tea manufactured from bought leaves, and if the increased business income is eligible for deduction under Section 80-IE.

Which sections of the Income-tax Act were involved?

Section 80-IE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, GUWAHATI BENCH, GUWAHATI

For Appellant: Shri S.K. Tulsiyan, Advocate
For Respondent: Shri Santosh Kumar Karnani, Addl. CIT
Hearing: 30.06.2026Pronounced: 16.07.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

This is an appeal filed by the assessee against the order passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Addl./Joint Commissioner of Income Tax (Appeals), Aurangabad [hereinafter referred to as “the Ld. CIT(A)] dated 28.11.2025, DIN & order No. ITBA/APL/S/250/2025-26/1083100458(1) on the following grounds of appeal:

2 Bagrodia Plantations and Industries Pvt. Ltd. “1. The order passed by the learned Commissioner of Income Tax (Appeals) is bad in law, contrary to facts and circumstances of the case, and

The order continues below.

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