DCIT, CIRCLE 4(2), NEW DELHI vs. M/S CNH INDUSTRIAL (INDIA) PVT LTD, UTTAR PRADESH
Before: MS. MADHUMITA ROY, & SHRI NAVEEN CHANDRA
PER NAVEEN CHANDRA, A.M:-
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
ITA No. 305/DEL/2025 [A.Y. 2023-24]
[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.”
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
ITA No. 305/DEL/2025 [A.Y. 2023-24]
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
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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).
9. In the result, the appeal of the Revenue in ITA No. 305/DEL/2025
is dismissed.
The order is pronounced in the open court on 04.09.2025. [MADHUMITA ROY]
[NAVEEN CHANDRA]
JUDICIAL MEMBER
ACCOUNTANT MEMBER
Dated: 15th October, 2025. VL/