SAEL LIMITED,FARIDKOT ROAD GURUHARSAHAI vs. DCIT, CC-1, LUDHIANA
What did the Tribunal hold?
The Tribunal observed that the additions were protective in nature for the assessee and that substantive additions in a connected case (M/s Gobind Dham Renewable Energy Pvt. Ltd.) on the same issues were subsequently deleted by the ITAT. Considering these judicial developments and the principles of natural justice, the Tribunal set aside the CIT(A)'s order and remitted the entire matter back for de novo adjudication on merits, directing the assessee to cooperate and provide all relevant records.
What were the facts?
The assessee's assessment for AY 2018-19, completed under section 143(3), included additions for CSR expenses, donations, employee benefits, leave encashment, and restricted set-off of brought-forward losses. The CIT(A) confirmed these additions ex-parte and on merits, relying on prior protective additions in the assessee's hands and substantive additions in a related entity, M/s Gobind Dham Renewable Energy Pvt. Ltd. The assessee failed to present an ITAT order for the related entity during CIT(A) proceedings.
What were the issues?
Whether protective additions in the assessee's case can survive when substantive additions in a related entity on the same issues have been deleted by the Tribunal, warranting a fresh adjudication on merits.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cause title — parties, addresses and appearances
आदेश/Order PER LALIET KUMAR, J.M: This appeal filed by the assessee, M/s SAEL Limited is directed against the order dated 29.03.2025 passed by the Ld. Pr. CIT (Appeals)-5, Ludhiana for the assessment year 2018-19. 2. In the present appeal Assessee has raised the following grounds: That, the orders passed by the Ld. Commissioner of Income Tax (Appeal) vide orders dated 29.03.2025 is illegal, uncalled for and against the law & facts.
That, the Ld. Commissioner of Income Tax (Appeal) has sustained th
The order continues below.
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