M/S GURU NANAK RICE MILLS,NAKODAR vs. INCOME TAX OFFICER, NAKODAR

ITA 103/ASR/2019Status: DisposedITAT Amritsar05 February 2026AY 2013-14Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL (Accountant Member), SHRI UDAYAN DASGUPTA (Judicial Member)5 pages
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What did the Tribunal hold?

The tribunal restored most issues, including TP adjustment, penalty under Section 271G, cash credits, and capital contributions, back to the CIT(A) for de novo adjudication, citing the ex-parte nature of previous orders and the assessee's willingness to present its case. However, a minor ad-hoc disallowance for car expenditure was upheld.

What were the facts?

The assessee, M/s Guru Nanak Rice Mills, challenged quantum additions related to Transfer Pricing (TP) adjustment, cash credits, and capital contributions, as well as a penalty under Section 271G. The lower authorities confirmed these additions and penalties, largely due to the assessee's non-compliance and ex-parte proceedings.

What were the issues?

The key legal issues involved the validity of Transfer Pricing adjustments and related penalties, the substantiation of cash credits and capital contributions, and the appropriateness of an ad-hoc disallowance for personal expenses, all in the context of ex-parte proceedings.

Which sections of the Income-tax Act were involved?

Section 92CA,Section 143(3),Section 144C,Section 271G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH, AMRITSAR

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

Heard together (3 matters)

ITA No.103/ASR/2019
ITA No.104/ASR/2019
ITA No.105/ASR/2019

Read from the judgment's own cause title. This page is filed under one of them.

Manoj Kumar Aggarwal (Accountant Member)

1.

In these appeals, the assessee assails confirmation of quantum additions as well as confirmation of penalty u/s 271G. First, we take up quantum appeal ITA No.103/Asr/2019 which arises out of an order

of Learned Commissioner of Income Tax (Appeals)-2, Jalandhar [CIT(A)] dated 31-10-2018 in the matter of an assessment framed by Ld. AO

The order continues below.

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