BILATIBARI TEA COMPANY PVT. LTD.,,UTTAR DINAJPUR vs. ACIT, CIRCLE 2, , JALPAIGURI

ITA 548/KOL/2025Status: DisposedITAT Kolkata22 December 2025AY 2013-14Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey, Judicial Member Bilatibari Tea Company Pvt. Ltd...... N S Road, Islampur Bazar, PO & PS. Islampur, Dist. Uttar Dinajpur, W.B-733202. [PAN: AABCB9014B] Appellant vs. ACIT, Circle-2, Jalpaiguri.......................................................Respondent Appearances by: Shri Rajib Mukherjee & Sujit Basu, Advocate, appeared on behalf of the appellant. Smt. Ruchika Sharma, Sr. DR, appeared on behalf of the Respondent. Date of3 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the Assessing Officer/CPC acted beyond jurisdiction by making the adjustment u/s 143(1)(a) without any arithmetical error in the return and without issuing a notice u/s 143(2). Finding that the assessee had correctly computed its total income, the Tribunal concluded that the adjustment was not sustainable in law. Consequently, the order passed u/s 143(1)(a)(ii) was quashed, and the addition was deleted.

What were the facts?

The assessee, a black tea manufacturer, filed its income tax return for AY 2013-14 with a total income of Rs.38,74,130/-. The CPC processed the return and made an adjustment of Rs.1,62,31,115/- to the returned income u/s 143(1)(a)(ii), increasing the total income to Rs.2,01,05,285/-. This adjustment was made by disallowing business expenditures and adjusted depreciation.

What were the issues?

Whether the adjustment made by the Assessing Officer/CPC under Section 143(1)(a)(ii) for disallowing expenditures was valid when there was no arithmetical error in the return and no notice under Section 143(2) was issued, and if the AO/CPC exceeded its jurisdiction.

Which sections of the Income-tax Act were involved?

Section 250,Section 143(1)(a),Section 143(1)(a)(i),Section 143(1)(a)(ii),Section 143(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH KOLKATA

Before: Shri Rajesh Kumar & Shri Pradip Kumar Choubey

Per Pradip Kumar Choubey, Judicial Member:

This appeal filed by the assessee is directed against the order dated 05.03.2025 of the National Faceless Appeal Centre (hereinafter referred to as the “CIT(A)”) passed u/s 250 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) for the assessment year 2013–14. 2. The only issue raised in the grounds of appeal that the A.O/CPC erred in disallowing a sum of Rs.1,62,31,155/- in the return of the assessee by way of adjustme

The order continues below.

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