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“advance tax”

Chapter XVII - Collection & Recovery (Advance tax)Chapter XVII-CSection 2(1) / Chapter XVII-C / ITR Schedule IT1,785 judgments

The decision most relied on for advance tax is Bajaj Tempo Ltd. v. CIT (196 ITR 188), cited in 289 judgments on BharatTax.

Leading authorities on advance tax

Bajaj Tempo Ltd. v. CIT
196 ITR 188 · 1992 · Supreme Court
289
citing judgments

Provisions in taxing statutes that grant incentives, concessions, or exemptions for promoting economic growth and industrialization must be interpreted liberally and purposively. Any restrictions placed on such provisions should also be construed reasonably to advance their objective, not frustrate it.

DIT v. GE Packaged Power Inc.
373 ITR 65 · 2015 · High Court
199
citing judgments

Interest under section 234B for default in payment of advance tax is not leviable when the entire income is subject to tax deduction at source under section 195, as no advance tax liability arises for the assessee in such circumstances.

Sreenivas Charitable Trust v. Dy. CIT
280 ITR 357 · 2006 · High Court
182
citing judgments

The expression "sufficient cause" for condoning delay in filing appeals must receive a liberal and purposive construction. This approach aims to advance substantial justice, which is of paramount importance.

Pradip Kumar Malhotra v. CIT
338 ITR 538 · 2011 · High Court
152
citing judgments

Section 2(22)(e) of the Income Tax Act, which addresses deemed dividends, does not apply to loans or advances provided by a company to its shareholders if these transactions occur in the normal course of business, are driven by business expediency, or are made in consideration of a benefit conferred upon the company by the shareholder. Conversely, gratuitous loans or advances given to shareholders fall within the purview of this section.

DIT v. NGC Network Asia LLC
313 ITR 187 · 2009 · High Court
144
citing judgments

Where a duty is cast on the payer to deduct and pay tax at source under Section 195, the payee-assessee cannot be levied interest under Section 234B for failure to pay advance tax if the payer defaults on its TDS obligation. This principle may also extend to interest under Section 234C.

Topman Exports v. CIT
342 ITR 49 · 2012 · Supreme Court
121
citing judgments

Export incentives, such as DEPB (Duty Entitlement Pass Book) and advance license benefits, constitute income taxable on an accrual basis under Section 28 of the Income-tax Act. Profit arising on the transfer of DEPB is not eligible for deduction under Section 80HHC.

CIT v. Creative Dyeing & Printing Pvt. Ltd.
318 ITR 476 · 2009 · High Court
119
citing judgments

Genuine trade advances or amounts advanced for bona fide business transactions, driven by commercial expediency, do not fall within the definition of deemed dividend under section 2(22)(e) of the Income-tax Act.

CIT v. Raj Kumar
318 ITR 462 · 2009 · High Court
119
citing judgments

Genuine trade advances made by a company in the ordinary course of business to a shareholder do not fall within the definition of deemed dividend under Section 2(22)(e) of the Income-tax Act.

Judgments citing advance tax

Schineler India Pvt Ltd, Mumbai vs. Dcitrg 15(3) (2), Mumbai

In the result, ground no. 6 raised by the assessee is allowed

ITA 724/MUM/2022[2017-18]Status: DisposedITAT Mumbai31 Dec 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2017-18 Schindler India Pvt Ltd Dcit Schindler House, Main Street, Range 15(3) (2) Hiranandani Gardens, Powai, Vs. Mumbai Mumbai - 400076 (Pan: Aaecs1548J) (Appellant) (Respondent) Present For: Assessee : Ms. Chandani Shah, Ms. Niddhi Agarwal & Ms. Riddhi Maru, Cas Revenue : Shri Ajay Chandra, Cit Dr Date Of Hearing : 08.10.2025 Date Of Pronouncement : 31.12.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Final Assessment Order Passed By National Faceless Assessment Centre, Delhi (Nfac) Vide Order No. Itba/Ast/S/143(3)/2021-22/1040015716(1) Dated 22.02.2022 U/S. 143(3) R.W.S. 144C(13) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”) Pursuant To The Directions Of Ld. Dispute Resolution Panel-2, Mumbai, (Drp) Vide Order No. Itba/Drp/F/144C(5)/2021-22/1039079646(1), Dated 25.01.2022, Passed U/S. 144C(5), For Assessment Year 2017-18. 2. Grounds Taken By Assessee Are Reproduced As Under: “Ground I. Legal Grounds

For Appellant: Ms. Chandani Shah, Ms. Niddhi Agarwal and Ms. Riddhi Maru, CAsFor Respondent: Shri Ajay Chandra, CIT DR
Section 143(3)Section 144C(5)Section 92CSection 92C(3)

erred in not granting TDS credit of Rs. 11,87,37,971, TCS credit of Rs. 37,278/- and advance tax of Rs. 60,90,59,436/- to the Appellant. 3.2 He failed to appreciate and ought to have held that the prepaid taxes

Haryana Urban Development Authority, Panchkula, Haryana vs. Principal Commissioner of Income Tax, Panchkula, Haryana

In the result, the appeal filed by the assessee is dismissed

ITA 668/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh29 Dec 2025AY 2021-22
For Respondent: Ms. Rattan Kaur & Shri A.K. Jindal, C.A's
Section 263Section 37Section 37(1)Section 43B

Tax or interest is found due on the basis of such return, after adjustment of any Tax deducted at source, any advance Tax paid and any amount paid otherwise by way of Tax or interest, then, without prejudice to the provision of sub-section (2), an initiation shall be sent ... Tax or interest is found due on the basis of such return, after adjustment of any Tax deducted at source, any advance Tax paid and any amount paid otherwise by way of Tax or interest, then, without prejudice to the provisions of sub-section (2), an intimation shall be sent

Mbg Commodities Private Limited, Hyderabad vs. ACIT., Circle -5(1), Hyderabad

ITA 657/HYD/2025[2014-15]Status: DisposedITAT Hyderabad26 Dec 2025AY 2014-15

Bench: Us:

For Appellant: Shri B. Satyanarayana, C.AFor Respondent: Ms. K. Haritha, CIT-DR
Section 142(1)Section 143(2)Section 144BSection 147Section 148Section 69A

with the so called bogus Companies. 9. The learned Commissioner of Income Tax erred in ignoring the ground for direction for proper credits to advance tax, self-assessment tax and regular tax paid by the Appellant Company for the year under consideration.” 2. Succinctly stated, the AO, based on information

Samsara Shipping Pvt Ltd, Mumbai vs. DCIT, Circle 3(1)(1), Mumbai

In the result, the appeal is allowed as indicated above

ITA 6724/MUM/2025[2021-22]Status: DisposedITAT Mumbai23 Dec 2025AY 2021-22

Bench: Shri Saktijit Dey & Shri Jagadishsamsara Shipping Pvt. Ltd. Income Tax Officer Room No. 607, 6Th Floor, 101/102, Technopolis Knowledge Park, Mahakali Caves Road, Vs. Aayakar Bhavan, M. K. Road, Chakala Midc S.O., Mumbai Mumbai-400 093 Pan/Gir No. Aaacs 9285 Q (Appellant) : (Respondent) Appellant By : Shri Sandeep Bhalla & Shri Sagar Joshi Respondent By : Shri Arun Kanti Datta Date Of Hearing : 18.12.2025 Date Of Pronouncement : 23.12.2025 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee, Against The Order Dated 27.08.2025 Of Addl./Jcit(A), Panchkula, Pertaining To The Assessment Year (A.Y.) 2021-22. 2. The Sole Grievance Of The Assessee In The Appeal Is Concerning Levy Of Interest U/S. 220(2) Of The Income Tax Act, 1961 (‘The Act’ For Short). Of Course, Vide Letter Dated 17.12.2025 The Assessee Has Sought To Raise An Additional Ground, Challenging The Validity Of The Order Passed U/S. 154 Of The Act On Account Of Non-Mentioning Of Document Identification Number (Din). Be That As It May, We Propose To Deal The Issue On Merits.

For Appellant: Shri Sandeep Bhalla &For Respondent: Shri Arun Kanti Datta
Section 143(1)Section 143(3)Section 154Section 156Section 220(1)Section 220(2)

section 220 of the Act provides that any 4 Samsara Shipping Pvt. Ltd. vs. ITO amount, other than amount payable by way of advance tax, specified in a demand issued u/s. 156 of the Act shall be paid within 30 days from the service of such notice on an assessee

Brig Resolution Services Private Limited, Mumbai vs. Circle 14(1)(2), Mumbai

In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes

ITA 6361/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Dec 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2020-21

For Appellant: Mr. Sunil HirawatFor Respondent: 01/12/2025
Section 143(1)Section 154

dedcutor, not deducted by the dedcutor, then the same was required to be same was required to be paid by assessee way of the advance tax. paid by assessee way of the advance tax. The identical issue has The identical issue has been decided by the Tribunal in the case

Income Tax Officer 23.2.1, Mumbai vs. Mig Co Op Housing Society Group II Ltd., Mumbai

ITA 4075/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Dec 2025AY 2014-15

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Chaitanya Joshi, AR
Section 143(3)Section 45Section 80PSection 80P(2)(c)Section 80P(2)(d)

taxation by the members of the Society, which though had been claimed by the assessee before the ld. CIT(A) stating that the advance tax for the sale of additional 10 & ½ flats have been paid by the members of the Society , so the Society would not be not liable

Dushyantbhai Ranchhodbhai Patel, Ahmedabad vs. The Dy.CIT, Circle-2(1)(1), Ahmedabad

In the result, appeal filed by the assessee stands allowed

ITA 1721/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad17 Dec 2025AY 2014-15

Bench: SHRI SANJAY GARG (Judicial Member)

For Appellant: Shri Jaimin Shah, A.RFor Respondent: Shri Ravindra, Sr. DR
Section 132Section 147Section 148Section 153CSection 210Section 234ASection 250Section 271(1)(c)Section 69

requires to be drop. 10. That the appellant has neither committed default of Sec. 210 nor made any default in payment of advance tax and therefore unwanted interest charged u/s 234A, 234B, 234C and 234D requires to be deleted. 11. Your appellant craves leave to add, amend, deleted or alter

Vikrant, Shamli vs. Income Tax Officer, Ward-3(1)(4), Shamli

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 5129/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Vimal Kumar & Smt. Renu Jauhri

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Ms. Ankush Kalra, SR. DR
Section 144BSection 147Section 148Section 184Section 234ASection 250Section 271(1)

Appellant could not have foreseen the additions/ disallowances made and could not have included the same in current income for payment of Advance tax. The interest charged under various sections is also wrongly worked out. 3 | P a g e ITA No. 5125-5129/DEL/2025 Vikrantl VS. ITO Ward

Vikrant, Shamli vs. Income Tax Officer, Ward-3(1)(4), Shmali

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 5128/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Dec 2025AY 2016-17

Bench: Shri Vimal Kumar & Smt. Renu Jauhri

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Ms. Ankush Kalra, SR. DR
Section 144BSection 147Section 148Section 184Section 234ASection 250Section 271(1)

Appellant could not have foreseen the additions/ disallowances made and could not have included the same in current income for payment of Advance tax. The interest charged under various sections is also wrongly worked out. 3 | P a g e ITA No. 5125-5129/DEL/2025 Vikrantl VS. ITO Ward

Vikrant, Shamli vs. Income Tax Officer, Ward-3(1)(4), Shamli

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 5127/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri Vimal Kumar & Smt. Renu Jauhri

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Ms. Ankush Kalra, SR. DR
Section 144BSection 147Section 148Section 184Section 234ASection 250Section 271(1)

Appellant could not have foreseen the additions/ disallowances made and could not have included the same in current income for payment of Advance tax. The interest charged under various sections is also wrongly worked out. 3 | P a g e ITA No. 5125-5129/DEL/2025 Vikrantl VS. ITO Ward

Vikrant, Shamli vs. Income Tax Officer, Ward-3(1)(4), Shamli

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 5126/DEL/2025[2014-15]Status: DisposedITAT Delhi17 Dec 2025AY 2014-15

Bench: Shri Vimal Kumar & Smt. Renu Jauhri

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Ms. Ankush Kalra, SR. DR
Section 144BSection 147Section 148Section 184Section 234ASection 250Section 271(1)

Appellant could not have foreseen the additions/ disallowances made and could not have included the same in current income for payment of Advance tax. The interest charged under various sections is also wrongly worked out. 3 | P a g e ITA No. 5125-5129/DEL/2025 Vikrantl VS. ITO Ward

Vikrant, Shamli vs. Income Tax Officer, Ward-3(1)(4), Shamli

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 5125/DEL/2025[2013-14]Status: DisposedITAT Delhi17 Dec 2025AY 2013-14

Bench: Shri Vimal Kumar & Smt. Renu Jauhri

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Ms. Ankush Kalra, SR. DR
Section 144BSection 147Section 148Section 184Section 234ASection 250Section 271(1)

Appellant could not have foreseen the additions/ disallowances made and could not have included the same in current income for payment of Advance tax. The interest charged under various sections is also wrongly worked out. 3 | P a g e ITA No. 5125-5129/DEL/2025 Vikrantl VS. ITO Ward

Sterlite Interlinks Limited, Gurugram vs. Deputy Commissioner of Income Tax, Circle-22(2), New Delhi

In the result, impugned order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 6838/DEL/2025[2021-22]Status: DisposedITAT Delhi16 Dec 2025AY 2021-22

Bench: Shri Vikas Awasthyआअसं.6838/धिल्ली/2025 (नि.व. 2021-22) Sterlite Interlinks Ltd., Rmz Infinity, 5Th Floor, Plot No. 15, Udyog Vihar, Phase Iv, Gurugram, Haryana 122015 ...... अपीलार्थी/Appellant Pan: Aazcs-6213-R बिाम Vs. Deputy Commissioner Of Income Tax, Circle22(2), ..... प्रनिवादी/Respondent Cr Building, Ip Estate, New Delhi 110002 अपीलार्थी द्वारा/Appellant By : S/Shri Rohit Jain, Deepesh Jain & Shaurya Jain, Advocates प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 16/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 16/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 25.08.2025, For The Assessment Year 2021-22. 2. Shri Rohit Jain, Appearing On Behalf Of The Assessee Submits That The Assessee Had Filed Return Of Income For Ay 2021-22 Declaring Total Income Of Rs.49,74,190/- . The Assessee In Its Return Of Income Had Claimed Refund Of Rs.3,01,52,020/-. The Return Of Assessee Was Processed U/S. 143(1) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’) & Intimation Dated 29.12.2022 Was Communicated To The Assessee Raising A Demand Of Rs.7,52,58,450/-. The Assessee

For Appellant: S/Shri Rohit Jain, Deepesh Jain &For Respondent: Shri Manoj Kumar, Sr. DR
Section 143(1)Section 154

आयकर अपीलीय अधिकरण धिल्ली पीठ “एस एम सी”, धिल्ली श्री धिकास अिस्थी, न्याधयक सिस्य IN THE INCOME TAX APPELLATE TRIBUNAL

Apmc Tarikere, Tarikere vs. Income Tax Officer, Ward-1, Chickmagalur

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 1442/BANG/2025[2017-18]Status: DisposedITAT Bangalore15 Dec 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Sri C.R. Vasanth Kumar, A.RFor Respondent: Sri Balusamy N., D.R
Section 10Section 10(1)Section 11Section 11(2)Section 11(7)Section 12ASection 139(1)Section 143(1)Section 143(2)Section 250

failure to mention the information regarding return filed for the assessment year in connection with which appeal is filed and whether an amount of advance tax as per section 249(4)(b) of the Act was paid and accordingly did not admit the appeal for adjudication on merit. 5. Again ... /NFAC erred in law in not admitting the appeal for a technical reason and the assessee is not liable to pay any advance tax since the assessee’s income is exempted u/s 10(26AAB) of the Act and also the assessee is a charitable trust and registered u/s 12AB

Kasturi Medical Centre Private Limited, Joka, Thakurpukur vs. Additional/Joint/Deputy/Assisstant Commissioner of Income Tax/Income-Tax Officer, Delhi

In the result the appeal of the assessee is allowed

ITA 318/KOL/2025[2018-19]Status: DisposedITAT Kolkata12 Dec 2025AY 2018-19

Bench: Shri Manunatha G & Shri Sonjoy Sarmai.T.A. No.318/Kol/2025 Assessment Year: 2018-19 Kasturi Medical Centre Pvt. Ltd……………….................................……….…Appellant 5, Diamond Harbour Road, 3A Bus Stand, Joka, Thakurpukur, W.B – 700104. [Pan: Aacck1872F] Vs. Acit, Nfac, Delhi…….…………..…………….…..….......……..…...…..…..Respondent Appearances By: Shri Indernil Banerjee, Fca, Appeared On Behalf Of The Revenue. Shri Soumitra Ghosh, Sr. Dr, Appeared On Behalf Of The Assessee. Date Of Concluding The Hearing : September 16, 2025 Date Of Pronouncing The Order : December 12, 2025 Order Per Sonjoy Sarma: This Appeal Is Filed By The Assessee Against The Order Of The Learned Cit(A) Passed For The Assessment Year 2018–19, Whereby The Addition Of ₹85,40,911 Made By The Assessing Officer On Estimated Basis After Rejection Of Books Of Account Under Section 145(3) Of The Income-Tax Act, 1961 Was Confirmed. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For Ay 2018–19 Declaring Total Income Of ₹2,05,59,220. The Case Was Selected For Complete Scrutiny Under The Scrutiny Assessment Scheme, 2019, Primarily On The Issue Of Large Refund Claimed Out Of Advance Tax. Accordingly, Notices Under Section 143(2) & Section 142(1) Of The Act Along With Questionnaires Were Duly Issued & Served.

Section 142(1)Section 143(2)Section 145(3)

case was selected for complete scrutiny under the Scrutiny Assessment Scheme, 2019, primarily on the issue of large refund claimed out of advance tax. Accordingly, notices under section 143(2) and section 142(1) of the Act along with questionnaires were duly issued and served. I.T.A. No.318/Kol/2025 Kasturi Medical Centre

Oceaneering International Gmbh, Mumbai vs. Deputy Commissioner of Income-Tax (International Taxation) Range 3(2)(2), Mumbai

ITA 6705/MUM/2025[2023-24]Status: DisposedITAT Mumbai12 Dec 2025AY 2023-24

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri A.K. JawadwalaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 143(3)Section 172Section 44B

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “I” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI SANDEEP

Sidhesh Mohan Raikar, Nashik vs. Deputy Director of Income Tax, Centralized Processing Centre, Banglore

In the result, the appeal filed by the assessee is allowed

ITA 294/PUN/2025[2023-24]Status: DisposedITAT Pune11 Dec 2025AY 2023-24

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.294/Pun/2025 Assessment Year : 2023-24

For Appellant: Shri Devendra JainFor Respondent: Shri Pramod Shahkar
Section 143(1)Section 154Section 199Section 5A

actually earned it.” 7. We further observe that the assessee in the ITR has claimed the TDS at ₹45,28,441 along with advance tax of ₹1,01,100 and Tax collected at source of ₹30,340. The CPC has duly given the credit of advance tax as well

Goldencross Pharma Limited, Mumbai vs. DCIT, Circle 7(1)(1) Current Jao- DCIT, Central Circle 1(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 4765/MUM/2025[2008-09]Status: DisposedITAT Mumbai10 Dec 2025AY 2008-09

Bench: Justice (Retd.) C. V. Bhadang & Shri Prabhash Shankargoldencross Pharma V/S. Deputy Commissioner Of Limited बनाम Income Tax, Circle 7(1)(1), Tower A, 1St Floor, Peninsula Current Jao-Dcit, Central Business Park, Ganpatrao Circle 1(2), Aaykar Bhavan, Kadam Marg, Lower Parel, Mk Road, Current Jao-906, Mumbai – 400013, 9Th Floor, Pratishtha Bhavan, Maharashtra Mk Road, Mumbai – 400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabcg0541J Appellant/अपीलार्थी .. Respondent/प्रतिवादी

Section 140ASection 143(3)Section 154Section 244A

resident/ foreign company. 38. Providing for payment of interest in case of refund of amounts paid as tax or deemed tax or advance tax is a method now statutorily adopted by fiscal legislation to ensure that the aforesaid amount of tax which has been duly paid in prescribed time

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

ITA 499/RJT/2025[2020-21]Status: DisposedITAT Rajkot08 Dec 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

For Appellant: Shri Prakash Jhunjhunwala and ShriFor Respondent: Shri Shramdeep Sinha, CIT.DR &
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

details were called for under e- assessment scheme. The assessee has stated that during the year under consideration, its tax liability for the advance tax purpose based on the average gross margin. The prices of palm oil have showed considerable hike resulted in reduction in our operating margin. The comparative ... food operated through dealer's network. Therefore, they could not be change their price and quantity frequently to match with raw materials prices. The advance tax calculated at assumption basis turned worn and refund of substantial amount was claimed. The reply filed by the assessee on this issue is acceptable

Gopal Snacks Pvt Ltd, Rajkot vs. Asst. Commissioner of Income Tax, Circle-1(1), Rajkot

ITA 498/RJT/2025[2015-16]Status: DisposedITAT Rajkot08 Dec 2025AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita Nos. 498 & 499/Rjt/2025 निर्धारणवर्ष /Assessment Years: 2015-16 & 2020-21 Gopal Snacks Pvt. Ltd. बनाम Asst. Commissioner Of Income Tax Circle-1(1), Rajkot Plot No.2322-2324, Gidc Metoda, Lodhika, Rajkot, Gujarat-360021 (अपीलार्थी/Appellant) Pan : Aadcg6113A (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राजस्व की ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 19/11/2025 घोषणा की तारीख/Date Of Pronouncement : 08/12/2025 Order Per, Dr. Arjun Lal Saini: Captioned Two Appeals Filed By The Same Assessee, Pertaining To

For Appellant: Shri Prakash Jhunjhunwala and ShriFor Respondent: Shri Shramdeep Sinha, CIT.DR &
Section 142(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 154Section 154(3)Section 250Section 80J

details were called for under e- assessment scheme. The assessee has stated that during the year under consideration, its tax liability for the advance tax purpose based on the average gross margin. The prices of palm oil have showed considerable hike resulted in reduction in our operating margin. The comparative ... food operated through dealer's network. Therefore, they could not be change their price and quantity frequently to match with raw materials prices. The advance tax calculated at assumption basis turned worn and refund of substantial amount was claimed. The reply filed by the assessee on this issue is acceptable