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“Section 155(19)”

Section References (mined)Section 155Section 155(19)33 judgments

The decision most relied on for Section 155(19) is CIT v. Tasgaon Taluka S.S.K. Ltd. (103 Taxmann.com 57), cited in 306 judgments on BharatTax.

Leading authorities on Section 155(19)

CIT v. Tasgaon Taluka S.S.K. Ltd.
103 Taxmann.com 57 · 2019 · Supreme Court
306
citing judgments

The Supreme Court holds that the issue of payment of excessive price on purchase of sugarcane by assesses is no longer res integra. The court elaborately dealt with this issue.

CIT v. Krishna Sahakari Sakhar Karkhana Limited
27 Taxmann.com 162 · 2012 · Supreme Court
263
citing judgments

The Supreme Court restores the matter for ascertaining whether the difference between the fair market price and concessional price of sugar supplied by a cooperative sugar factory to its members should be added to its total income, considering relevant factors like state cooperative society directions.

Judgments citing Section 155(19)

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2198/PUN/2024[2014-15]Status: DisposedITAT Pune15 Dec 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

appeal before Ld. CIT(A)/NFAC. It was also the contention of Ld. counsel of the assessee that there is an amendment in section 155(19) of the IT Act which permits the assessee to file rectification application before the Assessing Officer with regard to allowance of excess cane price

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2197/PUN/2024[2013-14]Status: DisposedITAT Pune15 Dec 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

appeal before Ld. CIT(A)/NFAC. It was also the contention of Ld. counsel of the assessee that there is an amendment in section 155(19) of the IT Act which permits the assessee to file rectification application before the Assessing Officer with regard to allowance of excess cane price

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2196/PUN/2024[2012-13]Status: DisposedITAT Pune15 Dec 2025AY 2012-13

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

appeal before Ld. CIT(A)/NFAC. It was also the contention of Ld. counsel of the assessee that there is an amendment in section 155(19) of the IT Act which permits the assessee to file rectification application before the Assessing Officer with regard to allowance of excess cane price

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2195/PUN/2024[2011-12]Status: DisposedITAT Pune15 Dec 2025AY 2011-12

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

appeal before Ld. CIT(A)/NFAC. It was also the contention of Ld. counsel of the assessee that there is an amendment in section 155(19) of the IT Act which permits the assessee to file rectification application before the Assessing Officer with regard to allowance of excess cane price

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2194/PUN/2024[2010-11]Status: DisposedITAT Pune15 Dec 2025AY 2010-11

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

appeal before Ld. CIT(A)/NFAC. It was also the contention of Ld. counsel of the assessee that there is an amendment in section 155(19) of the IT Act which permits the assessee to file rectification application before the Assessing Officer with regard to allowance of excess cane price

Shree Khedut Sahakari Khand Udyog Mandli Ltd., Bardoli vs. Income Tax Officer, Ward-1, Bardoli

ITA 738/SRT/2023[2012-13]Status: DisposedITAT Surat25 Nov 2025AY 2012-13

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

Section 143(3)Section 37(1)

same must be treated as Government approved price within the meaning of later legislative enactments such as section 36(1)(xvii) and section 155(19) of the Act, which reflect the legislative intention to treat Government approved cane price as allowable business expenditure. The AR submitted that these provisions, read ... same must be treated as Government approved price within the meaning of later legislative enactments such as section 36(1)(xvii) and section 155(19) of the Act, which reflect the legislative intention to treat Government approved cane price as allowable business expenditure. The AR submitted that these provisions, read

Maroli Vibhag Khand Udyog Sahakari Mandali Ltd, Na vs. Arivs.ACIT, Navsari Circle, Navsari

In the result, the four Revenue appeals in ITA Nos

ITA 17/SRT/2021[2012-13]Status: DisposedITAT Surat25 Nov 2025AY 2012-13

Bench: Shri Dinesh Mohan

Section 143(3)

same must be treated as Government approved price within the meaning of later legislative enactments such as section 36(1)(xvii) and section 155(19) of the Act, which reflect the legislative intention to treat Government approved cane price as allowable business expenditure. The AR submitted that these provisions, read ... subsequent legislative developments, viz. insertion of section 36(1)(xvii) by the Finance Act, 2015 (effective from AY. 2016-17), and insertion of section 155(19) by the Finance Act, 2023, as elaborated in the Memorandum to the Finance Bill and the CBDT SOP Circular dated 27.07.2023. He submitted that

ACIT, Na vs. Ari Circle, Navsarivs.M/S. Maroli Vibhag Khand Udyog Sahakari Mandali Ltd., Navsari

ITA 225/SRT/2020[2014-15]Status: DisposedITAT Surat25 Nov 2025AY 2014-15

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

Section 143(3)Section 37(1)

same must be treated as Government approved price within the meaning of later legislative enactments such as section 36(1)(xvii) and section 155(19) of the Act, which reflect the legislative intention to treat Government approved cane price as allowable business expenditure. The AR submitted that these provisions, read

ACIT, Na vs. Ari Circle., Navsarivs.M/S. Maroli Vibhag Khand Udyog Sahakari Mandali Ltd, Navasari

ITA 224/SRT/2020[2013-14]Status: DisposedITAT Surat25 Nov 2025AY 2013-14

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

Section 143(3)Section 37(1)

same must be treated as Government approved price within the meaning of later legislative enactments such as section 36(1)(xvii) and section 155(19) of the Act, which reflect the legislative intention to treat Government approved cane price as allowable business expenditure. The AR submitted that these provisions, read

ACIT, Na vs. Ari Circle, Navsarivs.M/S. Maroli Vibhag, Kand Udyog Sahakari Mandali Ltd., Navsari

ITA 222/SRT/2020[2011-12]Status: DisposedITAT Surat25 Nov 2025AY 2011-12

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

Section 143(3)Section 37(1)

same must be treated as Government approved price within the meaning of later legislative enactments such as section 36(1)(xvii) and section 155(19) of the Act, which reflect the legislative intention to treat Government approved cane price as allowable business expenditure. The AR submitted that these provisions, read

Sahakari Khand Uduog Mandal Ltd., Na vs. Arivs.DCIT, Navsari Circle, Navsari

ITA 213/SRT/2020[2013-14]Status: DisposedITAT Surat25 Nov 2025AY 2013-14

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

Section 143(3)Section 37(1)

same must be treated as Government approved price within the meaning of later legislative enactments such as section 36(1)(xvii) and section 155(19) of the Act, which reflect the legislative intention to treat Government approved cane price as allowable business expenditure. The AR submitted that these provisions, read

Sahadari Khand Udyog Mandal Ltd., Na vs. Arivs.ACIT, Navsari Circle, Navsari

ITA 212/SRT/2020[2012-13]Status: DisposedITAT Surat25 Nov 2025AY 2012-13

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

Section 143(3)Section 37(1)

same must be treated as Government approved price within the meaning of later legislative enactments such as section 36(1)(xvii) and section 155(19) of the Act, which reflect the legislative intention to treat Government approved cane price as allowable business expenditure. The AR submitted that these provisions, read

Sahakari Khand Udyog Mandal Ltd., Gandevi vs. ACIT, Navsari Circle, Navsari

ITA 211/SRT/2020[2011-12]Status: DisposedITAT Surat25 Nov 2025AY 2011-12

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

Section 143(3)Section 37(1)

same must be treated as Government approved price within the meaning of later legislative enactments such as section 36(1)(xvii) and section 155(19) of the Act, which reflect the legislative intention to treat Government approved cane price as allowable business expenditure. The AR submitted that these provisions, read

Shri Ganesh Sahakari Sakhar Kharkhana Limited, Ahmednagar vs. DCIT Ahmednagar Circle, Ahmednagar

ITA 119/PUN/2025[2009-10]Status: DisposedITAT Pune18 Aug 2025AY 2009-10

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.119/Pun/2025 निर्धारण वर्ष / Assessment Year : 2009-10 Shri Ganesh Sahakari Sakhar Karkhana Ltd., A/P. Ranjangaon Khurd, Tal.-Rahata, Dist.-Ahmednagar – 413719 Vs. Dcit, Ahmednagar Circle, Ahmednagar Pan: Aaeas0636H अपीलार्थी / Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / Ita Nos.2510, 2511 & 2512/Pun/2024 निर्धारण वर्ष / Assessment Years : 2010-11, 2012-13 & 2013-14 Shri Ganesh Sahakari Sakhar Karkhana Ltd., A/P. Ranjangaon Khurd, Tal.-Rahata, Dist.-Ahmednagar – 413719 Vs. Dcit, Ahmednagar Circle, Ahmednagar Pan : Aaeas0636H अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Hanmant Dattatry Dhavale Department By : Shri Amol Khairnar Date Of Hearing : 15-07-2025 Date Of Pronouncement : 18-08-2025 आदेश / Order Per Astha Chandra, Jm : The Above Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 20.12.2024 & 25.10.2024 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)"] Pertaining To Assessment Years ("Ays”) 2009-10 & 2010-11, 2012-13 & 2013-14 Respectively. For The Sake Of Convenience, All These Appeals Were Heard Together & Are Being Disposed Of By This Common Order. Ita No. 2510/Pun/2024 For Ay 2010-11 Is Taken Up As A Lead Case.

For Appellant: Shri Hanmant Dattatry DhavaleFor Respondent: Shri Amol Khairnar
Section 143(3)Section 144BSection 155(19)Section 254Section 40A(2)

ACIT in ITA Nos.67, 68 & 78/PUN/2024, order dated 16.05.2024 and considering the CBDT circular no.14 of 2023 dated 27.07.2023 and the provisions of section 155(19) of the Act. ITA Nos.119/PUN/2025 and 2510, 2511 & 2512/PUN/2024, AYs 2009-10 and 2010-11, 2012-13 & 2013-14- 3.2 As regards the sale ... sugar cooperatives to claim payments made to sugarcane farmers for the period prior to the AY 2016-17 as expenditure and accordingly, section 155(19) was inserted in the Act. The Ld. AR then referred to the provisions of section 155(19) of the Act which reads as under: “(19

Shri Ganesh Ssk Ltd, Ahmednagar vs. D.C.I.T, Ahmednagar, Circle-Ahmednagar

ITA 2512/PUN/2024[2013-14]Status: DisposedITAT Pune18 Aug 2025AY 2013-14

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Hanmant Dattatry DhavaleFor Respondent: Shri Amol Khairnar
Section 143(3)Section 144BSection 155(19)Section 254Section 40A(2)

78/PUN/2024, order dated 16.05.2024 and considering the CBDT circular no.14 of 2023 dated 27.07.2023 and the provisions of section 155(19) of the Act. AYs 2009-10 and 2010-11, 2012-13 & 2013-14 3.2 As regards the sale of sugar to its members by the assessee at concessional rate ... sugar cooperatives to claim payments made to sugarcane farmers for the period prior to the AY 2016-17 as expenditure and accordingly, section 155(19) was inserted in the Act. The Ld. AR then referred to the provisions of section 155(19) of the Act which reads as under

Shri Ganesh Ssk Ltd, Ahmednagar vs. D.C.I.T, Ahmednagar, Circle-Ahmednagar

ITA 2511/PUN/2024[2012-13]Status: DisposedITAT Pune18 Aug 2025AY 2012-13

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Department byFor Respondent: Date of hearing
Section 143(3)Section 144BSection 155(19)Section 254Section 40A(2)

ACIT in ITA Nos.67, 68 & 78/PUN/2024, order dated 16.05.2024 and considering the CBDT circular no.14 of 2023 dated 27.07.2023 and the provisions of section 155(19) of the Act. 3 ITA Nos.119/PUN/2025 and 2510, 2511 & 2512/PUN/2024, AYs 2009-10 and 2010-11, 2012-13 & 2013-14 3.2 As regards ... sugar cooperatives to claim payments made to sugarcane farmers for the period prior to the AY 2016-17 as expenditure and accordingly, section 155(19) was inserted in the Act. The Ld. AR then referred to the provisions of section 155(19) of the Act which reads as under

Shri Ganesh Ssk Ltd, Ahmednagar vs. D.C.I.T, Ahmednagar, Circle-Ahmednagar

ITA 2510/PUN/2024[2010-11]Status: DisposedITAT Pune18 Aug 2025AY 2010-11

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.119/Pun/2025 निर्धारण वर्ष / Assessment Year : 2009-10 Shri Ganesh Sahakari Sakhar Karkhana Ltd., A/P. Ranjangaon Khurd, Tal.-Rahata, Dist.-Ahmednagar – 413719 Vs. Dcit, Ahmednagar Circle, Ahmednagar Pan: Aaeas0636H अपीलार्थी / Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / Ita Nos.2510, 2511 & 2512/Pun/2024 निर्धारण वर्ष / Assessment Years : 2010-11, 2012-13 & 2013-14 Shri Ganesh Sahakari Sakhar Karkhana Ltd., A/P. Ranjangaon Khurd, Tal.-Rahata, Dist.-Ahmednagar – 413719 Vs. Dcit, Ahmednagar Circle, Ahmednagar Pan : Aaeas0636H अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Hanmant Dattatry Dhavale Department By : Shri Amol Khairnar Date Of Hearing : 15-07-2025 Date Of Pronouncement : 18-08-2025 आदेश / Order Per Astha Chandra, Jm : The Above Four Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 20.12.2024 & 25.10.2024 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)"] Pertaining To Assessment Years ("Ays”) 2009-10 & 2010-11, 2012-13 & 2013-14 Respectively. For The Sake Of Convenience, All These Appeals Were Heard Together & Are Being Disposed Of By This Common Order. Ita No. 2510/Pun/2024 For Ay 2010-11 Is Taken Up As A Lead Case. 2

For Appellant: Shri Hanmant Dattatry DhavaleFor Respondent: Shri Amol Khairnar
Section 143(3)Section 144BSection 155(19)Section 254Section 40A(2)

ACIT in ITA Nos.67, 68 & 78/PUN/2024, order dated 16.05.2024 and considering the CBDT circular no.14 of 2023 dated 27.07.2023 and the provisions of section 155(19) of the Act. 3 ITA Nos.119/PUN/2025 and 2510, 2511 & 2512/PUN/2024, AYs 2009-10 and 2010-11, 2012-13 & 2013-14 3.2 As regards ... sugar cooperatives to claim payments made to sugarcane farmers for the period prior to the AY 2016-17 as expenditure and accordingly, section 155(19) was inserted in the Act. The Ld. AR then referred to the provisions of section 155(19) of the Act which reads as under

Shri Ganesh Ssk Ltd, Ahmednagar vs. DCIT Ahmednagar Circle, Ahmednagar

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

ITA 2580/PUN/2024[2011-12]Status: DisposedITAT Pune31 Jul 2025AY 2011-12

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2011-12 Shri Ganesh Ssk Ltd. Dcit, Ahmednagar Circle A/P Ranjangaon Khurd, Vs. Tal. Rahata, Dist. Ahmednagar – 413719 Pan: Aaeas0636H (Appellant) (Respondent) Assessee By : Shri Hanmant Dattatray Dhavle Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 30-07-2025 Date Of Pronouncement : 31-07-2025 O R D E R

For Appellant: Shri Hanmant Dattatray DhavleFor Respondent: Shri Amol Khairnar, CIT-Dr
Section 143(3)Section 154Section 155(19)Section 40A(2)

Bapu Lad Sahakari Sakhar Karkhana Ltd. vs. ACIT vide ITA Nos.67, 68 & 78/PUN/2024, order dated 16.05.2024 and the provisions of section 155(19) of the Income Tax Act, 1961. 3 5. So far as the sugar sale at concessional rate is concerned, the Ld. CIT(A) / NFAC partly allowed ... opportunity to sugar cooperatives to claim payments made to sugarcane farmers for the period prior to the AY 2016-17 as expenditure Accordingly, Section 155(19) inserted in the Income Tax Act, 1961 which is read as follows” (19) Where any deduction in respect of any expenditure incurred

Shri Chhatrapati Sskltd, Pune vs. DCIT Circle-14, Pune

In the result, the appeal filed by the assessee in ITA

ITA 1924/PUN/2024[2009-10]Status: DisposedITAT Pune19 May 2025AY 2009-10

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1923 & 1924/Pun/2024 िनधा"रण वष" / Assessment Years : 2008-09 & 2009-10 Shri Chhatrapati Sahakari Vs. Dcit, Circle-14, Pune. Sakhar Karkhana Ltd., A/P. Bhavaninagar, Tal. Indapur, Dist. Pune- 413104. Pan : Aaaas3869G Appellant Respondent Assessee By : Shri Hanmant D. Dhavale Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 20.02.2025 Date Of Pronouncement : 19.05.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 07.08.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2008-09 & 2009-10 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1923/Pun/2024 For Assessment Year 2008-09 As A Lead Case For Adjudication.

For Appellant: Shri Hanmant D. DhavaleFor Respondent: Shri Ramnath P. Murkunde
Section 143(3)Section 154Section 155(19)

sugar at concessional rate. 6. After considering the reply of the assessee, Ld. CIT(A)/NFAC observed that in the light of section 155(19) of the IT Act and also in the light of CBDT Circular No.18/2021 dated 25.10.2021, the assessee is required to file an application ... assessee submitted before the Bench that the issue of allowance of excessive sugarcane purchase price has been settled by insertion of section 155(19) of the IT Act wherein the assessee is required to file an application under section 154 of the IT Act before the Assessing Officer to claim

Shri Chhatrapati Sskltd., Pune vs. DCIT Circle -14, Pune

In the result, the appeal filed by the assessee in ITA

ITA 1923/PUN/2024[2008-09]Status: DisposedITAT Pune19 May 2025AY 2008-09

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1923 & 1924/Pun/2024 िनधा"रण वष" / Assessment Years : 2008-09 & 2009-10 Shri Chhatrapati Sahakari Vs. Dcit, Circle-14, Pune. Sakhar Karkhana Ltd., A/P. Bhavaninagar, Tal. Indapur, Dist. Pune- 413104. Pan : Aaaas3869G Appellant Respondent Assessee By : Shri Hanmant D. Dhavale Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 20.02.2025 Date Of Pronouncement : 19.05.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 07.08.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2008-09 & 2009-10 Respectively. 2. Since The Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1923/Pun/2024 For Assessment Year 2008-09 As A Lead Case For Adjudication.

For Appellant: Shri Hanmant D. DhavaleFor Respondent: Shri Ramnath P. Murkunde
Section 143(3)Section 154Section 155(19)

sugar at concessional rate. 6. After considering the reply of the assessee, Ld. CIT(A)/NFAC observed that in the light of section 155(19) of the IT Act and also in the light of CBDT Circular No.18/2021 dated 25.10.2021, the assessee is required to file an application ... assessee submitted before the Bench that the issue of allowance of excessive sugarcane purchase price has been settled by insertion of section 155(19) of the IT Act wherein the assessee is required to file an application under section 154 of the IT Act before the Assessing Officer to claim