MITTAL RICE & GENERAL INDUSTRIES,AMBALA CITY vs. INCOME TAX OFFICER WARD 4 AMBALA , AMABALA CANT
Income Tax Appellate Tribunal, DIVISION BENCH, ‘A’ CHANDIGARH
Before: SHRI RAJPAL YADAV & SHRI MANOJ KUMAR AGGARWAL
PER RAJPAL YADAV, VP The assessee is in appeal before the Tribunal against the order of the ld. Commissioner of Income Tax (Appeals) [in short ‘the CIT (A)’] dated 18.09.2025 passed for assessment year 2017-18. 2. The solitary grievance of the assessee is assessee is that ld.CIT (Appeals) has erred in confirming the addition of A.Y.2017-18 2
Rs.30 lacs which was added by the AO on account of unexplained credits available in the bank account.
3. The brief facts of the case are that assessee has filed its return of income electronically on 31.03.2017. The case of the assessee was selected for scrutiny assessment by issuance of a notice u/s 143(2) on 26.09.2018. The AO has observed that during the demonetization period, a sum of Rs.72 lacs has been deposited on various dates in the Punjab
National Bank of the assessee. He issued a Show Cause
Notice to the assessee for explaining the source of deposit.
It was contended by the assessee that partnership firm is engaged in selling of rice and its turnover during the year was Rs.10,39,62,888/-. The money deposited in the bank account represent the sale consideration. Without making any analysis, ld. AO has accepted that Rs.42 lacs can be considered as representing the sale consideration and rest is to be treated as unexplained.
4. Appeal to the ld. CIT (Appeals) did not bring any relief to the assessee.
A.Y.2017-18
3
We fail to appreciate the fatuous exercise made by the AO, as there is no logic in the assessment order as to how he can identify that out of Rs.72 lacs, only Rs.42 lacs can be considered as sale proceeds of the rice. The turnover of the assessee is more than Rs.10.39 Cr. The AO has neither pointed out any defect in the books of account nor rejected the book results. The treatment made by the AO can only be termed as a high handedness while passing the assessment order. Therefore, we allow this appeal and delete the additions. 6. In the result, appeal of the assessee is allowed. Order pronounced on 16.03.2026. (MANOJ KUMAR AGGARWAL) VICE PRESIDENT
“Poonam”
आदेश कᳱ ᮧितिलिप अᮕेिषत/ Copy of the order forwarded to :
अपीलाथᱮ/ The Appellant 2. ᮧ᭜यथᱮ/ The Respondent 3. आयकर आयुᲦ/ CIT 4. िवभागीय ᮧितिनिध, आयकर अपीलीय आिधकरण, च᭛डीगढ़/ DR, ITAT, CHANDIGARH 5. गाडᭅ फाईल/ Guard File
सहायक पंजीकार/