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Section 2(24)(xvii)

Section References (mined)Section 2Section 2(24)(xvii)6 judgments

SAHYADRI FARMERS PRODUCER COMPANY LIMITED,NASHIK vs. PCIT, -1, NASHIK, NASHIK

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

ITA 1378/PUN/2025[2020-21]Status: DisposedITAT Pune14 Nov 2025AY 2020-21

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1378/Pun/2025 िनधा"रण वष" / Assessment Year : 2020-21 Sahyadri Farmers Producer Vs. Pcit-1, Nashik. Company Limited, Survey No.1102/8, Behind Police Head Quarter, Adgaon, Nashik- 422003. Pan : Aapcs1516D Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Amit Bobde Date Of Hearing : 21.08.2025 Date Of Pronouncement : 14.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.03.2025 Passed U/S 263 Of The Act By Ld. Pcit, Nashik-1 [‘Ld. Pcit’] For The Assessment Year 2020-21. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. The Learned Pcit-1, Nashik Erred In Law & On Facts In Assuming Jurisdiction U/S 263 Of The Ita, 1961 On The Analogy That The Order Passed U/S 143(3) Of The Ita, 1961 Dated 19/09/2022 Was Erroneous & Prejudicial To The Interest Of The Revenue. Grounds Relating To Government Grants:

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Amit Bobde
Section 143(3)Section 2(24)(xviii)Section 263Section 43(1)

passed by him. Ld. DR further submitted that the Assessing Officer failed to conduct any enquiry regarding non-applicability of provisions of section 2(24)(xvii) of the Act and also failed to conduct any enquiry with regard to External Commercial Borrowing (ECB). Ld. DR also submitted before the Bench

Section 2(24)(xvii) — 6 judgments | BharatTax | BharatTax