KANGAROO IMPEX,KARUR vs. A/DCIT, CIRCLE-2(1), TRICHY

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ITA 3747/CHNY/2025Status: DisposedITAT Chennai16 April 2026AY 2012-134 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the order of the CIT(A) which had dismissed the assessee's appeal. The dismissal was based on a previous appeal against the same assessment year having already been disposed of, rendering the current appeal infructuous.

What were the facts?

The assessee, a partnership firm engaged in the home textile industry, claimed expenditure on outsourced functions like weaving and stitching. The Assessing Officer disallowed 10% of this expenditure for failure to furnish complete details.

What were the issues?

Whether the appeal was maintainable when a prior appeal for the same assessment year was already decided. The validity of the disallowance of expenditure was not adjudicated on merits.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, CHENNAI BENCHES “B” :: CHENNAI

Before: SHRI INTURI RAMA RAO & SHRI MANU KUMAR GIRI

For Respondent: Ms. Gouthami Manivasagam, Addl.CIT
Hearing: 12/03/2026Pronounced: 16/04/2026

आयकर अपीलीय अिधकरण ”बी” �ायपीठ चे�ई म�। IN THE INCOME TAX APPELLATE TRIBUNAL CHENNAI BENCHES “B” :: CHENNAI BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI MANU KUMAR GIRI, JUDICIAL MEMBER आयकर अपील सं. / ITA No.3747/CHNY/2025 िनधा�रण वष� / Assessment Year: 2012-13 Kangaroo Impex, Vs A/DCIT, S F No.1726 Andankovil (PO), Circle -2(1), Tiruchirappalli. Amaravathi Nagar, Karur – 639002. PAN: AADFK6391H Appellant/ Assessee Respondent / Revenue Assessee by Mr.A.Sittarasu – Advocate Revenue by Ms. Gouthami Manivasagam, Addl.CIT Date of hearing 12/03/2026 Date of pronouncement 16/04/2026 आदेश/ ORDER PER INTURI RAMA RAO, AM : This appeal filed by the Assessee directed against the order of ld.Commissioner of Income Tax(Appeal) Chennai-20, dated 29.07.2025 passed under section 250 of the Income Tax Act, 1961 for the A.Y.2012- 13.

2.

The Revenue raised the following grounds of appeal : “A. M/s Kangaroo Impex is of Home Textile Industry. It outsources certain functions such as Weaving. Stitching, Mending & Packing jobs to outside persons on a piece rate basis. The total amount payable per individual, per week, anything between Rs.3,000 and Rs.5,000. Wherever the payment per person, per year, exceeds the thresh hold limit of Rs.75.000 or where one time payment exceeds Rs.30,000 per event, TDS has been deducted and deposited with the Govt., account. However, salient particulars such as quantity, rate & amount paid are mentioned and also the place of residence of the individual piece rate worker was given. As per normal practice in textile industry, the nature of business demands payment through cash and obtaining the signatures on the vouchers from the individuals.

B. Assessing Officer had erred in disallowing 10% of the total expenditure on such contractual laborers in ad-hoc basis as non- genuine is improper and incorrect. The order passed by the AO is liable to be quashed as it has no basis to disallow 10% after getting all the details. We request the Hon'ble Tribunal to set aside the order as the disallowance is arbitrary.”

2.

Briefly the facts of the case are that the respondent assessee is a Partnership Firm under Partnership Act, 1932. It is engaged in the business of Om Textiles. The Return of Income for the Assessment Year 2012-13 was filed on 18.01.2013 disclosing income of Rs.3,11,580/-. Against the said return of income, the assessment was completed by the DCIT, Circle- 2(1), Tirchy (hereinafter called ‘AO’) vide order dated 30.03.2015 passed u/s.143(3) of the Income Tax Act at a total income of Rs.15,89,350/-. While doing so, the Assessing Officer disallowed 10% of the expenditure claimed under heads “weaving, stitching, dyeing, mending, bleaching, loom charges etc.,’ of Rs.1,27,77,706/- for the failure of the appellant to furnish the details as called-for by the Assessing Officer for the verification of the expenditure.

3.

Being aggrieved by the above order, an appeal was filed before the ld.CIT(A) who vide order dated 29.07.2025 dismissing the appeal. Again, another appeal was filed on 20.05.2015. The ld.CIT(A) had dismissed the appeal as the appeal against the same impugned order was already dismissed vide appeal in ITA No.201/CIT(A)-20/2025-26 vide order dated 29.07.2025. We do not find any infirmity in the findings of the ld.CIT(A) since the appeal against the same assessment year was already disposed of, the present appeal was rightly dismissed as infructuous, accordingly, we uphold the order of ld.CIT(A).

3.

In the result, appeal of the assessee is dismissed. Order pronounced in the open Court on 16th April, 2026.

Sd/- Sd/- (MANU KUMAR GIRI) (INTURI RAMA RAO) JUDICIAL MEMBER ACCOUNTANT MEMBER Chennai; �दनांक / Dated : 16th April, 2026 SGR, Sr.PS आदेश क� ��त�ल�प अ�े�षत / Copy of the Order forwarded to : अपीलाथ� / The Appellant. 1. ��यथ� / The Respondent. 2. 3. The CIT Chennai/Madurai/Coimbatore/Salem. �वभागीय ��त�न�ध,आयकर अपील�य अ�धकरण, “सी” ब�च, 4. चे�नई/ DR, ITAT Chennai. गाड� फ़ाइल / Guard File. 5.

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