The Edara Primary Agricultural Cooperative Credit Society Private Limited Vs ITO (ITAT Visakhapatnam)
The Income Tax Appellate Tribunal (ITAT), Visakhapatnam, disposed of three appeals filed by a Primary Agricultural Cooperative Credit Society relating to Assessment Years (AYs) 2015-16, 2016-17 and 2017-18. Since the appeals for AYs 2015-16 and 2016-17 involved identical facts and issues, they were decided through a consolidated order.
AYs 2015-16 and 2016-17
The assessee, engaged in providing credit facilities to its members and selling fertilizers and allied goods, had not filed a regular return of income. Based on information showing cash deposits of ₹1.42 crore in its savings bank account, reassessment proceedings were initiated under Section 147. In response to the notice under Section 148, the assessee filed a return declaring nil income and explained that the cash deposits represented receipts from members, including cash recoveries of loans and advances granted to members in earlier years. However, the Assessing Officer treated the entire cash deposits as unexplained money under Section 69A because supporting documents such as the cash book, audit reports and other evidence were not produced for verification.
The Commissioner (Appeals) dismissed the appeal, observing that the assessee had failed to effectively pursue the appeal or furnish the required books of account, audit reports and financial documents despite several opportunities. The addition of ₹1,42,84,915 under Section 69A was therefore confirmed.
