SRI RAMA AGRI GENETICS (INDIA) PRIVATE LIMITED,KURNOOL vs. DCIT., CIRCLE-1, KURNOOL

ITA 1179/HYD/2025Status: DisposedITAT Hyderabad21 January 2026AY 2015-1633 pages
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What did the Tribunal hold?

The Tribunal held that the disallowance of seed purchases was excessive, especially considering the nature of the business and the evidence provided. The Tribunal also addressed the disallowance of ROC charges, allowing partial relief.

What were the facts?

The assessee, engaged in agri-seeds business, appealed against the disallowance of certain expenses, including seed purchases and ROC charges. The Assessing Officer (AO) made significant additions, which were partly confirmed and partly deleted by the Commissioner of Income Tax (Appeals).

What were the issues?

The key issues were the genuineness of seed purchases from farmers without PAN numbers and the nature of ROC charges as revenue or capital expenditure.

Which sections of the Income-tax Act were involved?

Section 37(1),Section 36(1)(iii),Section 68,Section 41(1),Section 143(3),Section 263

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Income Tax Appellate Tribunal, Hyderabad “B” Bench, Hyderabad

PER MANJUNATHA G., A.M : This appeal filed by the assessee is directed against the order of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [in short “NFAC”], Delhi, dated 11.06.2025, pertaining to the assessment year 2015-16. 2. The grounds raised by the assessee read as under :

“1. The Ld. CIT(A) erred in disa

The order continues below.

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