THE ITO, WARD-1, PALAKKAD, PALAKKAD vs. M/S. SNOFIELD FOODS PRIVATE LIMITED, PALAKKAD
In the result, the appeal filed by the Revenue is dismissed
ITA 837/COCH/2022[2006-2007]Status: DisposedITAT Cochin03 Mar 2023AY 2006-2007
Bench: Shri George George K. & Ms. Padmavathy S.The Income Tax Officer -1 Vs M/S. Snofield Foods Pvt. Ltd. Aayakar Bhavan Door No. V/623B, Marutharode English Church Road Village, Kuppayode Road Palakkad 678014 Marutharode, Palakkad 678007 Pan – Aafcs3164B (Appellant) (Respondent) Assessee By: Shri P.M. Veermani, Ca Revenue By: Smt. J.M. Jamuna Devi, Sr. Dr Date Of Hearing: 28.02.2023 Date Of Pronouncement: 03.03.2023 O R D E R Per: George George K., J.M. This Appeal At The Instance Of The Revenue Is Directed Against The Order Of The Cit(A)/Nfac, Delhi Dated 02.06.2022. The Relevant Assessment Year Is 2006-07. 2. Revenue Has Raised The Following Grounds Of Appeal: - “1) The Learned Commissioner Of Income Tax(Appeals) Erred In Deleting The Addition Made By Assessing Officer U/S 41(1), Has Not Gone Into The Merits Of The Issue Simply Relying On The Fact That The Similar Issue Is Already Decided In Favour Of The Assessee In The Case Of Sister Concerns. 2) The Learned Commissioner Of Income Tax (Appeals) Has Not Taken Into Consideration That The Assessee Should Have Credited Percentage Of Deduction Of The Freezer Deposit Every
For Appellant: Shri P.M. Veermani, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 143(3)Section 41(1)
46,61,636/- which is the 20% forfeiture of liability every year cumulatively for the AY 2001-02 upto 2005-06. The AO therefore made an addition of Rs.3,54,67,159/- in the assessment completed under Section 143(3) r.w.s. 254 o the Act (order dated 30.03.2014).
5. Aggrieved by the order of the AO, assessee filed appeal before