M/s River Valley Flour Mills Pvt. ltd. Vs. ACIT, Central Circle -1

Parties Involved

Facts Summary

The assessee, M/s River Valley Flour Mills Pvt. ltd., was subjected to a search action under section 132(1) of the Income Tax Act on 17.08.2014. The search covered the residential and business premises of the Gupta Nutrition Group, of which the assessee is a part. The group is involved in manufacturing and selling atta, maida, sujji, bran, etc., and has been a pioneer in establishing flour mills in Bihar. During the search, the assessee submitted a written statement under section 132(4) of the Act on 12.05.2016. Subsequently, the Assessing Officer (AO) issued a notice under section 143(2) and a questionnaire on 31.08.2016. The assessee disclosed an undisclosed income of ₹86,51,551/- during the assessment proceedings, leading to the imposition of a penalty under section 271AAB of the Act. The penalty was confirmed by the Commissioner of Income Tax, Patna-3 (CIT(A)) on 31.12.2024.…

Legal Issues

• 1. Whether the levy of penalty u/s 271AAB of the Act by the AO is justified when no satisfaction about the undisclosed income was recorded.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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