Jai Bhavani Reti Utpadak Sahakari Sanstha Ltd. Vs ITO, Ward-4(1), Thane

Parties Involved

Facts Summary

The assessee, Jai Bhavani Reti Utpadak Sahakari Sanstha Ltd., raised multiple grounds of appeal against the assessment order of the ld. CIT(A)/NFAC dated 20.08.2025 for A.Y. 2016-17. The main grounds of appeal were the addition of Rs. 27,00,000/- under section 69A, disallowance of deduction under section 80P, and not allowing credit of TDS shown in form 26AS. The assessee argued that no show cause notice was issued before making the addition under section 69A and that the disallowance under section 80P was unjustified due to a mismatch in PAN numbers. The Revenue argued that the assessee failed to provide sufficient evidence to prove the identity, creditworthiness, and genuineness of the transaction.…

Legal Issues

• 1. Addition of Rs. 27,00,000/- under section 69A
• 2. Disallowance of deduction under section 80P

Judgment Outcome

Decided in favour of Assessee.

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