DUGDH UTPADAK SAHAKARI SAMITI LIMITED,KALADERA vs. ITO 7(1), BABA SIDDHINATH BAWAN, JAIPUR
What did the Tribunal hold?
The Tribunal noted that the assessee subsequently provided a loan statement from Sundaram Finance Limited. The matter was restored to the Assessing Officer to examine this statement and other relevant documents to decide the issue afresh.
What were the facts?
The assessee purchased a vehicle for Rs. 21,90,000. Rs. 12,90,000 was paid by cheque, and the remaining Rs. 9,00,000 was claimed to be financed by Sundaram Finance Limited. The Assessing Officer disallowed this amount for lack of supporting documents.
What were the issues?
Whether the disallowance of Rs. 9,00,000 for vehicle purchase was justified without considering the loan statement from the finance company.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, JAIPUR BENCHES, “SMC” BENCH, JAIPUR
P a g e | 1 ITA No.1591/JPR/2025 Dugdh Utpadak Sahakari Samiti Limited IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “SMC” BENCH, JAIPUR BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER ITA No.1591/JPR/2025 (Assessment Year:2020-21) Dugdh Utpadak Sahakari Vs. ITO 7(1), Samiti Limited, Jaipur Kaladera �थायीलेखासं./जीआइआरसं./PAN/GIR No:AAAAD8858J Appellant .. Respondent Appellant by : Mrs. Suhani Meharwal, CA (thr. V.C.) Respondent by : Sh. Gautam Singh Choudhary, JCIT Date of Hearing 17.03.2026 Date of Pronouncement 19.05.2026 O R D E R The present appeal has been preferred by assessee against the order of National Faceless Appeal Centre (NFAC)/Ld. Commissioner of Income Tax (Appeals) (hereinafter referred to as “Ld. CIT(A)”) dated 25.08.2025, passed u/s 250 of the Income Tax Act, 1961 (in short “the Act”). 2. The sole issue involved in this appeal is relating to the disallowance of Rs.9,00,000/- made by the Assessing Officer on the ground that the assessee could not furnish the source of the said amount expended for purchase of a vehicle. The Assessing Officer (AO) noted that the
P a g e | 2 ITA No.1591/JPR/2025 Dugdh Utpadak Sahakari Samiti Limited assessee had incurred a total expenditure of Rs.21,90,000/- for purchase of vehicle. The assessee explained that Rs.12,90,000/- was paid by cheque from his Bank account and the remaining amount of Rs.9,00,000/- was got financed from Sundaram Finance Limited. The AO disallowed the expenditure to the extent of Rs.9,00,000/- observing that the assessee had not furnished the relevant documents to prove that the said amount was got financed from Sundaram Finance Limited.
The Ld. CIT(A) dismissed the appeal of the assessee by way of an ex parte order.
I have heard the rival contentions of the parties and gone through the record. The learned counsel for the assessee has furnished before this Tribunal a copy of the statement of the loan given to the assessee by Sundaram Finance Limited, showing that the assessee had taken a loan of Rs.9,00,000/- from Sundaram Finance Limited for purchase of Mahindra FURIO 14 vehicle. Though, the copy of statement was not furnished by the assessee before the AO, however, a perusal of the said statement prima facie reveals that the assessee had taken loan for the purchase of vehicle.
In view of this, the impugned order of Ld. CIT(A) is set aside, however, the matter is restored to the file of the AO with a direction to examine the aforesaid loan statement and other relevant documents in this respect furnished by the assessee and thereafter to decide this issue afresh. If the assessee is able to prove that the assessee has taken loan
P a g e | 3 ITA No.1591/JPR/2025 Dugdh Utpadak Sahakari Samiti Limited of Rs.9,00,000/- from Sundaram Finance Limited, no addition will be warranted.
In the result, the appeal of the assessee is treated as allowed for statistical purposes. Order is pronounced under provision of Rule 34 of ITAT Rules, 1963 on 19/05/2026.
Sd/- (Sanjay Garg) Judicial Member Dated 19.05.2026 Mittali, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT By Order,
Asst. Registrar ITAT, Jaipur
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