GAJANAN AGROFEEDS P LTD,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIR-1 (2),, PUNE
In the result, appeal of the assessee is allowed for statistical purpose
ITA 298/PUN/2021[2014-15]Status: DisposedITAT Pune29 Sept 2022AY 2014-15
Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.298/Pun/2021 िनधा"रणवष" / Assessment Year : 2014-15 Gajanan Agrofeeds Pvt. Ltd., The Dcit, Cir-1(2), Pune. 3, Sushila Complex, Station Vs Road, Baramati, Pune – 413102. Pan: Aaccg 3651 Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 13/09/2022 Date Of Pronouncement 29/09/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)-1, Pune Dated 17.01.2020For The Assessment Year 2014-15 Arising Out Of The Order Of The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal: “1. On The Facts & In The Circumstances In The Case & In Law The Lower Authorities Erred In Rejecting The Additional Evidences Filled Under Section 46A Of The Income Tax Rules, 1961 Without Realizing The Fact That Such Additional Evidences Ought To Have Been Admitted As It Goes To The Root Cause Of Issue & Therefore, Prayer Is Made For Admission Of Additional Evidences. 2. On The Facts & The Circumstances In The Case & In Law The Lower Authorities Erred In Making Addition Of Rs.86,09,000/- Being Unsecured Loans From Sister Concern By Invoking Provisions Of Section 68 Of The Income Tax Act, 1961, By Rejecting The Submissions Made In This Regard & Also Additional Evidences Submitted.
Section 143(3)Section 46ASection 68
46A of the Income Tax Rules, 1961 without realizing the fact that such additional evidences ought to have been admitted as it goes to the root cause of issue and therefore, prayer is made for admission of additional evidences.
2. On the facts and the circumstances in the case and in law the lower authorities erred in making addition
