Sansar Agropol Pvt. Ltd. Vs ITO, Ward-2(2), Bhubaneswar

Parties Involved

Facts Summary

The assessee, Sansar Agropol Pvt. Ltd., is a private limited company engaged in the business of retail trading of agricultural seeds. The company filed its income return on 29.03.2013, declaring total income at Rs.6,49,226/-. The assessment was completed by making various additions, determining the total income at Rs.2,02,80,110/-. The assessee had received advances against the supply of goods from 10 parties totaling Rs.1,88,71,000/-. These amounts were shown under the head 'unsecured loans' in the audited financial statements but were actually business advances received in the normal course of business. The assessee appealed against the order of the Commissioner of Income Tax (Appeals) dated 12.01.2024, challenging the addition of Rs. 1,88,71,000/- under 'unsecured loan creditors' and other disallowances.…

Legal Issues

• 1. Whether the Commissioner of Income Tax (Appeals) was justified in dismissing the ground raised by the appellant regarding the denial of adequate opportunity by the Assessing Officer while making huge additions in the assessment order.
• 2. Whether the Commissioner of Income Tax (Appeals) erred in law in confirming the huge addition of Rs. 1,88,71,000 made by the Assessing Officer under the head 'unsecured loan creditors'.
• 3. Whether the Commissioner of Income Tax (Appeals) erred in law in confirming the disallowances made by the Assessing Officer.

Judgment Outcome

Decided in favour of Assessee.

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