KAIDVANA MUVADA P DUDH UTPADAK SAHKARI MANDALI LIMITED,PANCHMAHAL vs. THE ITO, WARD-1, GODHRA

ITA 2325/AHD/2025Status: DisposedITAT Ahmedabad10 March 2026AY 2019-20Bench: SHRI SIDDHARTHA NAUTIYAL (Judicial Member), SHRI NARENDRA PRASAD SINHA (Accountant Member)6 pages
AI SummaryAllowed for statistical purposes

What did the Tribunal hold?

The Tribunal condoned the 393-day delay in filing the appeal, acknowledging the genuine difficulties faced by the assessee. It observed that the CIT(A) erred by dismissing the appeal ex-parte without adjudicating the merits. Consequently, the Tribunal remanded the matter back to the Assessing Officer for fresh de-novo consideration, directing that the assessee be given an opportunity to explain the cash withdrawals in light of its business activities.

What were the facts?

The assessee, a rural milk co-operative society, did not file its return of income, leading to a reassessment where cash withdrawals of ₹86,25,000/- were added as unexplained expenditure under Section 69C. The CIT(A) confirmed the addition ex-parte due to non-compliance by the assessee, which the assessee attributed to difficulties in accessing digital notices. The assessee claims these cash withdrawals were legitimate business payments to rural milk vendors.

What were the issues?

Whether the CIT(A) erred in confirming additions ex-parte without adjudicating merits; whether cash withdrawals by a milk society for vendor payments constitute unexplained expenditure under Section 69C; and condonation of delay in filing appeal.

Which sections of the Income-tax Act were involved?

Section 69C,Section 115BBE,Section 250(6),Section 271AAC,Section 234A,Section 234B,Section 234F

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, AHMEDABAD

Before: SHRI SIDDHARTHA NAUTIYAL & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri Mehul K. Patel, Advocate
For Respondent: Shri C Dharani Nath, Sr. DR
Hearing: 09.03.2026Pronounced: 10.03.2026

PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER:

This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi vide order dated 06.08.2024 passed for A.Y. 2019-20. 2. The assessee has taken the following grounds of appeal:

“1.0 The learned Commissioner of Income Tax (Appeals), NFAC has erred in law and on facts in passing the appellate order ex-parte, without ensuring that a real and meaningful opportunity of hearing was afforded to the appellant, especially considering the peculiar circumstanc

The order continues below.

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