Saroday Farmer Producer Company Ltd. Vs ITO (ITAT Pune)
The assessee filed an appeal before the ITAT Pune against the order of the CIT(A)/NFAC, Delhi passed under Sections 143(3) read with Sections 144B and 250 of the Income Tax Act for Assessment Year 2023-24. The appeal challenged the ex parte order of the CIT(A), which had sustained the addition made by the Assessing Officer.
The assessee is a Farmer Producer Company Limited registered under the Companies Act, 2013 and engaged in production, harvesting, procurement, grading, pooling, handling, marketing, sale and export of agricultural produce of its members, as well as import of goods or services for their benefit. It filed its return of income for AY 2023-24 on 30.09.2023 declaring nil income after claiming deduction of ₹6,23,954 under Section 80PA of the Income Tax Act. The case was selected for scrutiny under CASS, and the Assessing Officer issued notice under Section 142(1) along with a show cause notice. In response, the assessee furnished documents including the certificate of incorporation, memorandum and articles of association, audit report, CC and OD statements, computation of income, profit and loss account, balance sheet with notes and bank statements. However, according to the Assessing Officer, the assessee failed to substantiate its claim for deduction under Section 80PA with supporting evidence. Consequently, the Assessing Officer disallowed the deduction of ₹6,23,954, assessed the total income at ₹6,23,954 and passed the assessment order under Section 143(3) read with Section 144B on 22.03.2025.
