ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY vs. VIJAY DAIRY AND FARM PRODUCTS PRIVATE LIMITED, MUSIRI, TRICHY

आयकर अपीलीय अिधकरण, ‘ए’
यायपीठ, चे ई।
IN THE INCOME TAX APPELLATE TRIBUNAL
‘A’ BENCH: CHENNAI

ी एबी टी. वक
, ाियक सद एवं
एवं
एवं
एवं

ी मनोज कुमार अवाल, लेखा सद के सम

BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRI MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER

आयकर अपीलसं./ITA Nos.266 & 275/Chny/2024
िनधारणवष/Assessment Years: 2016-17 & 2018-19

The ACIT,
Central Circle-1,
Trichy.

v.
M/s.Vijay Dairy &
Farm Products Pvt. Ltd.,
Trichy-Thuraiyur Main Road,
Peramangalam,
Musiri Tk.,
Trichy-621 006. [PAN: AAACV 2113 N]
(अपीलाथ/Appellant)

(यथ/Respondent)

Department by :
Mr. Nilay Baran Som, CIT
Assessee by :
Mr. N. Arjun Raj, Advocate
सुनवाईक तारीख/Date of Hearing
:
29.01.2025
घोषणाक तारीख /Date of Pronouncement
:
19.03.2025

आदेश / O R D E R
PER ABY T. VARKEY, JM:

These are appeals preferred by the Revenue against the order of the Learned Commissioner of Income Tax (Appeals), (hereinafter referred to as “the Ld.CIT(A)”), Chennai-19, dated 12.12.2023 and 14.12.2023 for the Assessment Years (hereinafter referred to as "AY”) 2016-17 & 2018-
19 respectively. Both sides agreed that the facts as well as the issues permeating in both the appeals are being dispo
2. With the consent which will mutatis muta
3. The Revenue has 1 The order of the learn on facts of the case and 2 The Ld. CIT(A) erre
26.75% of GP of unacco data and RoI) quantified
2.1 The CIT(A) erred in with regard to sales, w sales as 109.75 crores figure as per SAP data return of income, the a Crores and again ded reconciliation furnished
2.2 The CIT(A) failed t
FOC Invoices, discounts of accounts with sales a not produced any evide proceedings.
3. For these grounds a that may be raised dur learned CIT(Appeals) m restored.
4. Ground No.1 is adjudication.
5. Ground No.2 is a addition of profit of Rs.1
ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 2 ::

e appeals are the same and therefo sed off by this common order.
of both the parties, we have taken
4 for AY 2016-17 as the lead case a ndis apply for AY 2018-19 as well.
raised the following grounds for AY ned Commissioner of Income Tax (Appeals) is er d in law.
d in deleting the addition of Rs.1,90,57,625/
ounted sales of Rs.7,12,43,457 (difference betw d in the assessment order.
n accepting the reconciliation furnished by the a without appreciating that the assessee has arr after deducting sales returns of 1.23 crores fro a of 110.98 Crores. But while reconciling sales ssessee has taken sales figures as per books at ducted sales return of Rs.1.23 Crores. He by the assessee is not correct.
to appreciate that the assessee company has s N credit notes while reconciling the sales as pe admitted in the returns of income and the asses ences in support of such claims during the ass nd any other ground including amendment of ring the course of the appeal proceedings, the may be set aside and that of the Assessing O general in nature which does no against the action of the Ld.CIT(A 1,90,57,625/- made in relation to th

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2016-17 & 2018-19) rm Products Pvt. Ltd.

ore, both these n the appeal in nd the result of 2016-17:
rroneous
/-, being ween SAP assessee rived net om Sales s as per t 109.75
nce the claimed er books ssee had sessment grounds order of fficer be ot require any A) deleting the he unaccounted sales of Rs.7,12,43,457
data and the sales repo
5.1
The brief facts as Company which had file
16.10.2016, admitting t a survey u/s.133A of th
"the Act”) upon the ass the AO is noted to have issue of notice u/s.148
have declared the sam income filed u/s 139
assessment completed
AO made additions on a way of unexplained inve
(ii) gross profit on Aggrieved, the assesse was pleased to delete b
5.2
Aggrieved, the R pointed out by the Ld. A of the Ld.CIT(A) deletin made u/s.69 of the Act
ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 3 ::

7/- viz., difference between the sa rted in the return of income.
s noted are that, the assessee is a ed its Return of Income [RoI] for A total income of Rs.1,04,34,539/-. L e Income Tax Act, 1961 (hereinafte sessee on 19.02.2019. Consequent reopened the assessment for the re of the Act. In response, the asses me income as originally declared in of the Act. It is noted that, in t u/s 147/143(3) of the Act dated 2
account of, (i)difference towards m estment u/s.69 of the Act of Rs.2,4
difference in sales data of Rs e preferred an appeal before the oth these additions.
Revenue is now before us. At the AR that the Revenue has not challen g the addition on account of unexpl to the tune of Rs.2,40,30,245/-; an 66 & 275/Chny/2024
2016-17 & 2018-19) rm Products Pvt. Ltd.

les as per SAP
Private Limited
AY 2016-17 on Later, there was er referred to as t to the survey, elevant year by see is noted to n the return of he income tax
24.03.2022, the ilk purchase by 40,30,245/- and .1,90,57,625/-.
Ld.CIT(A), who outset, it was nged the action lained purchase nd that the only addition in dispute is Rs.1,90,57,625/-.
5.3
The facts relating
133A of the Act, the s the data relating to sal the SAP software. The the Income- Tax Return software and found dif noted to have confron
(Finance), Shri S.C.Pan to clarify the same and AO is noted to have o assessee company wa discrepancy in the sale give proper explanation team, the AO had reope
Before the AO, the ass statement along with c noted to have rejected
Rs.7,12,43,457/- betwe and that this constitut
ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 4 ::

the deletion of profit on unacco to this issue are that, in the cours urvey team came across the comp les were maintained by the assess survey team had compared the sa n (ITR) with the sales data maintai fference of Rs.7,12,43,457/-. The s nted this discrepancy with the Ge neerselvam, who according to the A sought additional time to furnish t bserved that, even the Executive s unable to furnish any suitable es. Hence, since the assessee com n about the discrepancy in the sales ened the impugned assessment u/s sessee is noted to have furnished certain details/ supporting’s. The A the same and held that difference een SAP data and ITR data remain ted suppressed sales of the asse

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2016-17 & 2018-19) rm Products Pvt. Ltd.

unted sales of e of survey u/s puters, wherein see company in ales reported in ned in the SAP survey team is eneral Manager
AO, was unable the details. The Director of the reply for the mpany failed to s to the survey
147 of the Act.
a reconciliation
AO however is in the sales of ed unexplained essee. The AO accordingly worked out gross profit of 26.75%
total income. On appea
Now the Revenue is in a 5.4
Before us the Ld.
CIT(A) on two counts.
assessee was not corre earlier computed net sa of Rs.1.23 Crs. from s
According to him theref as per SAP data at Rs.
Rs.1.23 Crs was erro furnished by the asses
Ld. CIT, DR was that, showing that the sales sales as per ITR was ne but satisfactory details reconciliation statement
5.5
Per contra, the Ld
Ld. CIT(A). The Ld. AR indeed maintaining its a ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 5 ::

t the profit embedded in the suppr i.e. Rs.1,90,57,625/- and added th al, the Ld.CIT(A) was pleased to de appeal before us.
CIT, DR has primarily assailed the o
The first being, the reconciliation ct, as according to him, the assess ales of Rs.109.75 Crs. after deducti sales figure as per SAP data of fore, the action of the assessee tak
.109.75 Crs. and again, deducting oneous, and it showed that the see wasn’t correct. The second co though the assessee had reconcile as per SAP data was the gross figu et off sales return, FOC invoices, cre in support of the same was not file t was bald and therefore not tenable d. AR for the assessee supported th for the assessee explained that, the accounts using the SAP software bu

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2016-17 & 2018-19) rm Products Pvt. Ltd.

ressed sales at he same to the elete the same.
order of the Ld.
n given by the see had already ng sales-return
Rs.110.98 Crs.
ing sales figure sales-return of e reconciliation ntention of the ed the data by re and that the edit notes, etc., ed and that the e.
he order of the e assessee was ut the data was maintained in different m same, the Ld. AR subm recorded in the sales led will be shown in the register’. Similarly, th accounted in separate accounts are finalized, modules are merged an therefore submitted th higher in the SAP mo purposes of final acco discount, FOC invoices, figure reported in ‘Sales he took us through the figures indeed reconcil relevant facts has acce and gave a finding of f reported in SAP and addition. He accordingly call for any interference
ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 6 ::

modules of SAP accounting system.
mitted that if sales take places, th dger of the SAP system. Likewise, a separate ledger or module called he discounts, FOC invoices, cre
SAP modules. He thus showed us
, all the relevant ledgers in the nd the final figures are reported in T at, in the sales ledger, the sales dule, as it is the gross sum. Ho unts, the sales reported is net o credit notes etc., which is reduced s ledger’ of the SAP system. With th reconciliation statement and show ed and that, the Ld.CIT(A) after epted the reconciliation provided by fact that there is no difference bet the ITR and therefore, deleted y urged that the order of the Ld. C e.

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2016-17 & 2018-19) rm Products Pvt. Ltd.

Elucidating the e same will be ny sales-return d ‘Sales return edit notes are that, when the separate SAP ally system. He figure will be wever, for the of sales return, from the gross his explanation, ed us that, the examining the y the assessee ween the sales the impugned
CIT(A) does not 5.6
We have heard b before us. The issue in only question before us that the assessee had r
SAP data with the sales fact-based exercise. T which is found placed at CUSTOMER W
Total sales
Less: Sale Re and hence we arrive net sale
Sales as per S
Less As stated be deducted tw
Less: FOC Inv
Less: credit no Less: Price dif
Less: Sale o bags
Total Revenu per ITR

both the parties and perused the m nvolved in this appeal is in narrow s is whether the Ld. CIT(A) was just reconciled the difference between t s reported in ITR. This is noted to b he reconciliation statement filed by t Page No.230 of the Paper Book, is WISE SALES DATA report
11098,60
eturn in data it is positive e have to deduct twice to s
-123,53 Data - IT Dept
10975,07, d above Sales Return Data to wice
-123,53
voices & Credit note
-61,63
ote
-9,26
fference
-460,94
of SMP Conversion packing
-47
ue from operations - As 10319,22, on raised by the Ld. CIT, DR the sales as per SAP data was Rs.1
cording to him, the assessee had return of Rs.1.23 Crs twice and rom an apparent error. To this, the sales reported in SAP records seized rs and not Rs.110.98 crores. It wa

66 & 275/Chny/2024
2016-17 & 2018-19) rm Products Pvt. Ltd.

material placed w compass. The tified in holding he sales as per be essentially a y the assessee, as under:-
Rs.
,521
,029
,492
,029
,728
,626
,649
,429
,030
to the above
110. 98 Crs and d deducted the therefore the Ld. AR brought d by the survey as shown to us that, before the AO, t return to the sales as Rs.110.98 Crs (Rs.109
(Rs.109.75 Crs – Rs.1.2
the above reconciliation erroneous addition of R crores and, thereafter correct gross sales of R
Rs.108.51 crores. Havin this to be a classic c appearing for the Reve sales as per SAP recor
This figure of Rs.110. arithmetical mistake co sales return of Rs.1.23
instead of deducting it.
the figure of sales retu assessee, first to correc figure of Rs.110.98 cror thereafter, the sales re
Rs.109.75 crores to arr
ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 8 ::

the assessee had inadvertently ad s per SAP data and reported the .75 Crs + Rs.1.23 Crs) instead of 23 Crs). The Ld. AR accordingly poin n, this error was rectified by first
Rs.1.23 crores from the sales figur the sales return was correctly red
Rs.109.75 crores to arrive at the net ng perused the facts available on r case of unwanted confusion. The enue, was unable to controvert the rds was Rs.109.75 crores and not 98 crores is noted to have eman mmitted by the assessee wherein t
3 crores to the gross sales of Rs
. For this reason, in the reconciliat rn is noted to have been eliminate ct their mistake and bring down the res to correct sales figure of Rs.109
eturn was actually deducted from rive at net sales of Rs.108.51 crore

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2016-17 & 2018-19) rm Products Pvt. Ltd.

ded the sales- e net sales at Rs.108.51 Crs nted out that, in eliminating the re of Rs.110.98
duced from the t sales figure of record, we find e Ld. CIT, DR e fact that, the Rs.110.98 Crs.
nated from an they added the s.109.75 crores tion statement, ed twice by the e reported sales
9.75 crores and gross sales of es. Accordingly, we find this particular the assessee had righ arithmetical mistake in return was added to th there from, which was c
5.8
It is further note because the AO had on module of SAP system i which contained ledgers etc. We agree with the wherein data is maintai in Sales Ledger and th module called Sales R merged while finalizing reported in the financia across these different le
AO considered all the ledgers for sales return the main sales ledger, t figure reported in ITR. I
ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 9 ::

argument of the Revenue to be un htly pointed out that there was n the reconciliation statement whe e sales as per SAP data instead of corrected later.
ed that, the impugned difference nly considered the figure of sales r
.e. ‘Sales Register’ and had ignored s for sales return, discounts, FOC, p e assessee that it a common acco ined in different modules in SAP i.e he Sales Return will be in a sepa
Return Register etc. These separa the financial statements and ther ls/ITR are a summation of the amou edgers. We agree with the assesse different SAP modules, which cont
, discounts, FOC, price differences the net data would have reconciled
It is noted that, this aspect was rig

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2016-17 & 2018-19) rm Products Pvt. Ltd.

nsustainable as an inadvertent rein the sales- f being reduced in sales arose reported in one d other modules price differences unting practice e., sales will be rate Ledger or te ledgers are refore the sales unts mentioned e that, had the tained separate etc. along with d with the sales htly considered by the Ld. CIT(A) while by holding as under: -
“6.3.5
During submitted the rec
Sales as per book
Less: Items to be Sales Returns
FOC Invoices & N
Discounts – Price
SMP conversion B
Net Sales to be a As against the ab assessee is as un
Part A – P & L – I
Part A – P & L – I
Total Sales admit
6.3.6
Further has submitted th processing indus claimed that the sales will be in S
Ledger or modu overall control ov finalizing the acc reported in the T higher in the SAP to be reduced fro be taken into acc
6.3.7
The un
A.R. made durin
ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 10 ::

agreeing with the above reconciliat the course of Appellate Proceedings, t conciled sales amount as under:
ks of Accounts

107950
e considered:

12353029
N Credit Notes
7090354
Difference

46094649
Bags

47429
655854
dmitted in ITR

103192
bove, the Sales admitted in the ITR 6 uplo der:
Item 1 A i – Sale of Products
102626
Item 1 A ii – Sale of Services
5657
tted by the assessee

103192
r, the A.R. during the course of Appellate at SAP software is very much useful for co tries as in the case of the Appellant Co data is maintained in different modules in Sales Ledger and the Sales Return will be ule called Sales Return Register. This fa ver the processing in the industry. During t counts, both will be merged, and the fina
Tally. Obviously, in sales ledger, the sales
P module but for accounts purpose, the sal om the sales ledger. Thus, the reconciled ount for Income Tax purposes.
ndersigned carefully examined the subm g the course of Appellate Proceedings. B

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2016-17 & 2018-19) rm Products Pvt. Ltd.

tion statement, the A.R. has 07492
461
22031
oaded by the 64035
7997
22032
e Proceedings ontinuous and ompany, and SAP. For e.g.
in a separate acilitates the the course of al figures are figure will be es return has figure has to ission of the Based on the reconciliation pro between the sales one part of the SA
Appellant has sup
6.3.8
During not produced any filed ITR u/s 13
proceedings befo the AO has gross respect to the sal
AY 2016-17. In accept the observ estimating the Accordingly all th treated as allowe of Rs.1,90,57,625
5.9
We further obse relevant respective led before the lower autho the party wise details statement along with co sub-heads i.e. discount with sample vouchers.
reconciliation of the sal the Revenue was unabl according to us, corrob the AO didn’t point out was missing qua the r considered view that, th
ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 11 ::

ovided by the Appellant, there exists n s reported in the SAP and ITR. The A.O. ba
AP module has arrived an erroneous conclu ppressed the sales.
the course of Appellate proceedings, the a y new evidence other than what is decla
39(1) of the Act as well as in the re ore the AO. The Appellant has clearly est sly mistaken in arriving an erroneous sale les made by the appellant in the FY 2015-1
this back ground the undersigned is no vation of the AO in treating the sales as su gross profit out such alleged suppre he grounds raised by the appellant upon t ed and the AO is hereby directed to delete
5/- made as sales suppression for the A.Y.
rve that, the assessee had also gers as appearing in the books o rities. The assessee is also noted for each of the items in the abov opy of the accounts of major parties t, FOC invoices, price difference etc
. The assessee had also placed es turnover with the VAT returns. I e to point out any infirmity in these borated the above reconciliation st t any specific item or evidence, wh reconciliation statement. We are th hese details/supporting’s furnished b

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2016-17 & 2018-19) rm Products Pvt. Ltd.

no difference ased upon the usion that the appellant has red in the e- e-assessment ablished that es figure with 16 relevant to ot inclined to ppressed and essed sales.
this issue are e the addition
2016-17.”
furnished the of the accounts to have placed e reconciliation s under the said c. accompanied on record the It is noted that e details which, tatement. Even hich in his view herefore of the by the assessee were sufficient to corro there was no difference sales as per ITR recon
Revenue that, the rec backed by supporting’
discussed in the foreg dismissed. Hence, the dismissed.
6. We now take up
2018-19. Ground No. 1
does not require any sp
7. Ground No. 2 re the addition of profit unaccounted sales of R as per SAP data and th considering the rival s circumstances involved appeal in AY 2016-17. figure appearing in Rs.137,91,27,740/-, wh was Rs.130,19,14,906/
ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 12 ::

oborate the reconciliation statemen e in sales and that the sales as per nciled. Accordingly, the second con conciliation furnished by the asse
’s is found to be unjustified, on going. For these reasons, Ground e appeal of Revenue for AY 20
the appeal in ITA No.275/Chny
1 is noted to be general in nature a ecific adjudication.
lates to the Ld. CIT(A)’s action of pa of Rs.1,65,62,153/- made in r s.7,72,12,834/- viz., difference bet he sales reported in the return of submissions, it is observed that is identical to the Ground No. 2
Like in AY 2016-17, the AO obs
‘Sales
Ledger’
as per
SA hereas according to him, the sales
- and therefore the difference of Rs

66 & 275/Chny/2024
2016-17 & 2018-19) rm Products Pvt. Ltd.

nt showing that r SAP data and ntention of the essee was not n the facts as No. 2 stands
016-17 stands y/2024 for AY and is therefore artially deleting relation to the tween the sales income. After the facts and 2 of Revenue’s served that the AP data was reported in ITR s.7,72,12,834/- was held by him to be return. The AO accordi on such unaccounted s total income of the asse considered the reconcil with all the data module figure as per SAP data and after adding the contained in separate le
‘Sales Register’ modul reported in ITR w
Rs.130,19,14,906/-, as ‘Sales of services’ repo
Accordingly, the Ld. CIT sales figure between th restricted the addition being Rs.41,166/- as ag
Revenue is in appeal be 7.1
Following our con that in this AY as well reported in one modu
ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 13 ::

unaccounted sales not reported in ngly is found to have estimated pr sales and added sum of Rs.1,65,6
essee. On appeal, the Ld. CIT(A) is iation statement furnished by the es of SAP system and found that th net off sales return, discounts, FO sales figure sale of other produc edgers/modules, which didn’t form p e, was Rs.130,51,61,814/- and t was actually
Rs.130,49,69,897
s the AO had omitted to consider rted in Item 1(A)(ii)of Part-A P&L A T(A) is found to have worked out th e SAP data and ITR at Rs.1,91,917
of profit element to 21.45% of s gainst Rs.1,65,62,153/- added by th fore us.
nclusions drawn in A.Y. 2016-17 a , the AO had only considered the le of SAP system i.e. ‘Sales Reg

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2016-17 & 2018-19) rm Products Pvt. Ltd.

the income-tax rofit @ 21.45%
62,153/- to the s noted to have assessee along he correct sales
OC invoices etc.
cts & services, part of the main that, the sales
7/- and not r the figure of A/c of the ITR.
he difference in 7/- and thereby such difference he AO. Now the above, we find figure of sales gister’ and had ignored other module discounts, FOC, price d products & services. It merged while finalizing reported in the financia across these different le sales as per ITR, the AO and omitted to conside reported in the ITR. W considered all the diff ledgers for sales return the main sales ledger a reconciled with the sa except a minor differe assessee is noted to details, sample vouche reconciliation before the following findings of the furnished by the asses difference of Rs.1,91,91

ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 14 ::

es which contained ledgers for differences etc. and also ledgers of t is observed that, these separate the financial statements and ther ls/ITR are a summation of the amou edgers. It is also noted that, while
O had only considered the figure of er the figure for ‘sale of services’, w
We agree with the Ld. CIT(A) tha ferent SAP modules, which conta
, discounts, FOC, price differences and other sales ledgers, the net da les figure of goods & services re ence of Rs.1,91,917/-. Like in AY have furnished the relevant ledge ers, GST reconciliation etc. in su e lower authorities. We thus counte e Ld. CIT(A) analyzing the reconcilia ssee and holding it to be tenable
17/-;-

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2016-17 & 2018-19) rm Products Pvt. Ltd.

sales return, f sales of other e ledgers were refore the sales unts mentioned arriving at the f ‘sale of goods’
which was also at, had the AO ained separate etc. along with ata would have eported in ITR,
Y 2016-17, the ers, party-wise upport of their enance with the ation statement e, except for a 6.3.5
During submitted the rec
Sales as per Book
Less: Items to be Sales Returns
FOC Invoices &N
Discounts – Price

Add: Sales of Non
Sale of Cattle Fee
Sale of Tea Shop
Sale of Café Prod
Sales to be admit i) As against the the assessee is as Part A - P & L -Ite
Part A - P & L -Ite
Total Sales admit

the course of Appellate proceedings, t conciled sales amount as under:
ks of Accounts e considered:

103774824
Credit Notes
2236585
Difference

41450200

n Milk Products Not Included in Above:
ed

71819278
Products

704352
ucts

972053

tted in ITR e above, the Sales admitted in the ITR 6
s under:
em 1 A i - Sale of Products em 1 A ii - Sale of Services tted by the assessee r, the A.R. during the course of Appellate at SAP software is very much useful for co tries as in the case of the Appellant Co data is maintained in different modules in Sales Ledger and the Sales Return will be ule called Sales Return Register. This fa ver the processing in the industry. During t counts, both will be merged, and the fina
Tally. Obviously, in sales ledger, the sales
P module but for accounts purpose, the sal om the sales ledger. Thus, the reconciled ount for Income Tax purposes.
ndersigned carefully examined the subm g the course of Appellate Proceedings. B ovided by the Appellant, there exists es reported in the ITR and Sales to be a is Rs. 130,49,69,897/- and the sales to b
4/-. Thus there exits a shortfall in admis
1,91,917/-(130,51,61,814 - 130,49,69,89
sale not disclosed by the Appellant in r, the AO in the assessment order based u

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2016-17 & 2018-19) rm Products Pvt. Ltd.

the A.R. has 1379127740
147461609
1231666131
73495683
1305161814
uploaded by 1301914906
3054991
1304969897
e Proceedings ontinuous and ompany, and SAP. For e.g.
in a separate acilitates the the course of al figures are figure will be es return has figure has to ission of the Based on the a difference dmitted. The e admitted is ssion of sales
7) Obviously, its return of upon the one part of the SAP m
Appellant has sup
6.3.8
During not produced any filed ITR u/s 1
proceedings befo the AO has gross respect to the sal
AY 2018-19. In accept the observ estimating the gr reconciliation stat
Sales which was upon such differ
Appellant for th undisclosed sale
Accordingly all th treated as allow addition to the determined as un
7.2
For the above rea of Ld. CIT(A) and acco
Hence, the appeal of the 8. In the result, both

Order pronounced (मनोज कुमार अवाल
(MANOJ KUMAR AGGA
लेखासदय/ACCOUNTANT
चेई/Chennai,
दनांक/Dated: 19th March, 2
TLN
ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 16 ::

module has arrived at an erroneous conclu ppressed the sales to the extent of Rs.7,72, the course of Appellate Proceedings, the A y new evidence other than what is decla
39(1) of the Act as well as in the r ore the A.O. The Appellant has clearly est sly mistaken in arriving an erroneous sale les made by the Appellant in the FY 2017-1
this back ground the undersigned is no vation of the AO in treating the sales as su ross profit out such alleged suppressed sale tement there exist a difference of only Rs.
not disclosed in the Return of Income. The rence can only be the unaccounted inc he year under consideration. The GP s shall be ( 21.45% of Rs.1,91,917)R he grounds raised by the Appellant upon t wed and the AO is hereby directed to extent of Rs. 41,166/- as against Rs. 1
naccounted salesfor the AY 2018-19. asons, we see no reason to interfere rdingly, this ground of the Revenu e Revenue for AY 2018-19 also fails h the appeals filed by the Revenue a d on the 19th day of March, 2025, in ल)
ARWAL)
MEMBER (एबी टी.
(ABY T. VA
याियकसदय/JUDI
2025. 66 & 275/Chny/2024
2016-17 & 2018-19) rm Products Pvt. Ltd.

usion that the ,12,834/-.
Appellant has red in the e- reassessment ablished that es figure with 18 relevant to ot inclined to ppressed and es. As per the 1,91,917/- in e Gross Profit come of the upon such Rs. 41,166/-.
this issue are restrict the 1,65,62,153/- e with the order e is dismissed.
.
are dismissed.
Chennai.
/-
वक
)
ARKEY)
CIAL MEMBER

आदेश क ितिलिप अेिषत/Cop

ITA Nos.26
(AYs 2
M/s.Vijay Dairy & Far
:: 17 ::

py to:
nai / Madurai / Salem / Coimbatore.

66 & 275/Chny/2024
2016-17 & 2018-19) rm Products Pvt. Ltd.