NANGAL KHURD CO-OPERATIVE AGRICULTURAL SERVICE SOCIETY LIMITED,UNA vs INCOME TAX OFFICER,, UNA

Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: HON’BLE SHRI LALIET KUMAR, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2017-18 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 10-04-2024 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 147 r.w.s. 144 r.w.s. 144B of the Act on 20-09-2021. The registry has noted delay of 381 days in the appeal, the condonation of which has been sought by Ld. AR on the strength of condonation petition which is accompanied by an affidavit of the administrator of assessee-society. The Ld. Sr. DR has pleaded for dismissal of the appeal.

In the assessment order, Ld. AO made addition of cash deposits for Rs.24.09 Lacs u/s 69A for want of documentary evidences from the assessee. The Ld. CIT(A) confirmed the same for want of any compliances from the assessee. Aggrieved, the assessee is in further appeal before us. The only prayer of Ld. AR is to admit the appeal and restore the assessment back to the file of Ld. CIT(A) which has been opposed by Ld. Sr. DR. The Ld. AR stated that the assessee is in a position to substantiate the deposits, if another opportunity is granted to the assessee.

Keeping in mind the principles of natural justice and considering the fact that the assessee is a society of agriculturist, we admit the appeal and restore the appeal back to the file of Ld. CIT(A) for de novo adjudication with a direction to the assessee to plead and prove its case. All the issues are kept open.

The appeal stand allowed for statistical purposes. Order pronounced on 20th November, 2025.

NANGAL KHURD CO-OPERATIVE AGRICULTURAL SERVICE SOCIETY LIMITED,UNA vs. INCOME TAX OFFICER,, UNA