DCIT, CIRCLE 4(2), NEW DELHI vs. M/S CNH INDUSTRIAL (INDIA) PVT LTD, UTTAR PRADESH

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ITA 305/DEL/2025Status: DisposedITAT Delhi15 October 2025AY 2023-24Bench: MS. MADHUMITA ROY, JUDICIAL MEMBER, SHRI NAVEEN CHANDRA (Accountant Member)5 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal found that the CIT(A) had analyzed the issue, considering the evidence of a mistake in reporting Form 3CD, and had granted appropriate relief to the assessee. Therefore, the Tribunal declined to interfere with the CIT(A)'s order.

What were the facts?

The Revenue preferred an appeal against the CIT(A)'s order deleting an addition of Rs. 72,08,51,534/- made by the CPC. The addition arose from an alleged error in reporting the opening inventory balance in the Tax Audit Report, which was processed under Section 143(1).

What were the issues?

Whether the CIT(A) was correct in deleting the addition made by CPC due to an alleged error in the Tax Audit Report, and whether the assessee should have sought rectification from the AO first.

Which sections of the Income-tax Act were involved?

Section 143(1),Section 139(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI ‘B’ BENCH,

Before: MS. MADHUMITA ROY, & SHRI NAVEEN CHANDRA

For Respondent: Shri Shrikant Namdeo, CIT-DR
Hearing: 04.09.2025Pronounced: 04.09.2025

This appeal by the Revenue is preferred against the order of the ld. CIT(A), dated 07.01.2025 for A.Y 2023-24.

2.

The Revenue has raised the following grounds of appeal:

“1. Whether the Learned CIT(A) erred in deleting the addition of Rs. 72,08,51,534/- made by the Centralized Processing

Page 1 of 5 Center(CPC) in the intimation order under Section 143(1) of the Income Tax Act, 1961 dated 03.05.2024, without remanding the matter back to the Assessing Officer (AO) for Verification.

2. Whether the Learned CIT(A) failed to appreciate that the assessee did not fulfill its statutory obligation to file a revised Form 3CD to rectify the error in the Tax Audit Report as intimation by the CPC. [3. Whether the Learned CIT(A) overlooked the fact that the assessee chose to appeal directly without seeking rectification of the mistake with the AO, which was a more appropriate course of action in the given circumstances.

4. The appellant craves leave to add, alter or amend any/all of the grounds of appeal before or during the course of the hearing of the appeal.”

3.

None appeared for and on behalf of the assessee. Nor there was any application for adjournment. So we heard the ld. DR at length and perused the relevant material on record brought on record duly considered in light of Rule 18(6) of the ITAT Rules.

4.

Brief facts of the case are that the CNH Industrial (India) Private Limited (the assessee) is a company incorporated on 23.11.1992 and engaged in the business of manufacturing of motor vehicles, wholesale and retail sale of motor vehicles, other IT enable services. The assessee filed its original return of income on 30.11.2023 declaring total income

Page 2 of 5 of Rs. 6,84,72,14,425/- u/s 139(1) of the Income-tax Act, 1961 [the Act, for short] and claimed a refund of Rs. 57,960/-.

5.

The assessee received an intimation regarding proposed adjustment u/s 143(1)(a) of the Act on 06.12.2023 to which there was no response from the assessee. The assessee subsequently filed a grievance dated 21.03.2024 and stated the reasons why proposed adjustment should not be made. Subsequently, the return of income was processed under section 143(1) of the Act and intimation dated 03.05.2024 was issued by the Deputy Director of Income Tax, CPC, Bangalore without considering the grievance filed by the assessee, making additions amounting to Rs. 21,84,10,350/-.

6.

Aggrieved by the intimation u/s 143(1) of the Act, the assessee went in appeal before the ld. CIT(A) and contended that the tax auditor while filing TAR, has inadvertently reported (under clause 14(b) subhead “Increase in purchase cost of raw material and stores on inclusion of GST”) opening balance of inventory and stores for AY 2022-23 of Rs. 7,66,99,75,219/- instead of closing balance i.e. Rs. 8,39,08,26,761/- for AY 2022-23, resulting in deviation of Rs 72,08,51,534/-. Before the CIT(A), the assessee filed evidences to show that the addition is wrong

Page 3 of 5 and the CIT(A) allowed the grounds raised by the assessee and deleted the addition made by CPC of Rs 72,08,51,534/-.

7.

The Revenue is aggrieved and is before us.

8.

We have heard the ld DR and have perused the materials on record.

We find that the CIT(A), upon finding the evidence that there is mistake in reporting in Form 3CD, allowed the assessee’s appeal. We are therefore, of the view that the ld. CIT(A) has analyzed the issue of addition made by the CPC and has given appropriate relief to the assessee. We, therefore, decline to interfere with the order of the ld. CIT(A). is dismissed.

The order is pronounced in the open court on 04.09.2025.

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