KATIKATA SERVICE COOPERATIVE SOCIETY LTD,KATIKATA vs. INCOME TAX OFFICER, JAJPUR

ITA 191/CTK/2026Status: DisposedITAT Cuttack29 May 2026AY 2019-206 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that the assessee, a PACS, claimed the cash deposits belonged to its members but failed to substantiate this before the lower authorities. In the interest of justice, the issue was remitted back to the AO for fresh consideration with an opportunity for the assessee to provide supporting documents.

What were the facts?

The assessee, a Primary Agricultural Co-operative Society (PACS), failed to file its return of income despite substantial cash deposits in its bank account. The Assessing Officer (AO) made additions based on available material after the assessee did not respond to notices. The CIT(A) dismissed the assessee's appeal.

What were the issues?

Whether cash deposits in the bank account of a PACS represent unexplained money or legitimate business receipts/loan recoveries from members, and whether adequate opportunity was provided to the assessee to prove its case.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B,Section 69A,Section 56,Section 80P(2)(a)(i)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, CUTTACK BENCH, CUTTACK

For Appellant: Dr. Sanjay Behura, Shri Anant Narayan Singhbabu, ARs
For Respondent: Shri Rajesh Mishra, CIT-DR
Hearing: 27.04.2026Pronounced: 29.05.2026

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. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “the Ld. CIT(A)] dated

2 Katikata Service Cooperative Society Ltd. 18.12.2025, DIN & order No. ITBA/NFAC/S/250/2025- 26/1083852355(1) on the following grounds of appeal:

“1. That on the facts and in the circumstances of the case and in law, the learned Commissioner

The order continues below.

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