SAHYADRI FARMERS PRODUCER COMPANY LIMITED,NASHIK vs. PCIT, -1, NASHIK, NASHIK

ITA 1378/PUN/2025Status: DisposedITAT Pune14 November 2025AY 2020-21Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessment order was not a speaking order and the AO failed to conduct proper inquiries and verifications regarding government grants and ECB loans, making the order erroneous and prejudicial to the revenue. The Tribunal confirmed the PCIT's order directing the AO to reframe the assessment.

What were the facts?

The assessee company engaged in processing fruits and vegetables filed its return of income, which was selected for scrutiny. The Assessing Officer (AO) completed the assessment accepting the returned income. The Principal Commissioner of Income Tax (PCIT) initiated proceedings under Section 263 of the Income Tax Act, 1961, believing the AO's order was erroneous and prejudicial to the revenue.

What were the issues?

Whether the AO's assessment order was erroneous and prejudicial to the revenue due to lack of proper inquiry regarding government grants and ECB loans, warranting revision under Section 263.

Which sections of the Income-tax Act were involved?

Section 263,Section 143(3),Section 43(1),Section 144B,Section 119

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “B”, PUNE

Before: SHRI MANISH BORAD & SHRI VINAY BHAMORE

For Appellant: Shri Kishor B. Phadke
For Respondent: Shri Amit Bobde
Hearing: 21.08.2025Pronounced: 14.11.2025

PER VINAY BHAMORE, JM: This appeal filed by the assessee is directed against the order dated 27.03.2025 passed u/s 263 of the Act by Ld. PCIT, Nashik-1 [‘Ld. PCIT’] for the assessment year 2020-21. 2. The appellant has raised the following grounds of appeal :- “1. The learned PCIT-1, Nashik erred in law and on facts in assuming juri iction u/s 263 of the ITA, 1961 on the analogy that the order passed u/s 143(3) of the ITA, 1961 dated 19/09/2022 was erroneous and prejudicial to the interest of the revenue. Grounds relating to Government grants:

2

2.

The learned PCIT-1, Nashik erred in law and on facts in not appreciating the fact that all the details/informa

The order continues below.

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