KAMLA ASSOCIATES,SHEOPUR vs. ACIT-3(1), GWALIOR

ITA 371/AGR/2025Status: DisposedITAT Agra09 April 2026AY 2011-125 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the issue of advances required fresh verification. It also noted that the nature of payments made to Escorts Limited, which were disallowed under Section 40(a)(ia) for non-deduction of TDS, needed to be determined as either interest or bill discounting charges.

What were the facts?

The assessee, a tractor dealer, received advances in cash from farmers for tractor sales. The Assessing Officer treated these advances totaling Rs. 1,05,65,000 as unexplained cash credits under Section 68. The CIT(A) sustained additions of Rs. 87,58,300 for certain parties.

What were the issues?

Whether cash advances received by a tractor dealer are unexplained cash credits, and the applicability of Section 40(a)(ia) to bill discounting charges paid without TDS.

Which sections of the Income-tax Act were involved?

Section 68,Section 143(3),Section 40(a)(ia)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AGRA BENCH “DB”: AGRA

For Appellant: Shri Anurag Sinha, Adv
For Respondent: Shri Anil Kumar, Sr. DR
Hearing: 17/03/2026Pronounced: 17/03/2026

PER M. BALAGANESH, A. M.:

1.

The appeal in ITA No.371/AGR/2025 for AY 2011-12, arises out of the order of the ld National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘ld. CIT(A)’, in short] dated 24.06.2025 against the order of assessment passed u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 29.11.2013 by the Assessing Officer, ACIT, Circle-3, Gwalior (hereinafter referred to as ‘ld. AO’).

2.

The Ground Nos. 3 to 6 raised by the assessee are challenging the confirmation of addition by the Learned CIT(A) of Rs 87,58,300 under section 68 of the Act on account of alleged unexplained cash credits in respect of advances received against sale of tractors.

3.

We have heard the rival submissions and perused the materials available on

The order continues below.

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