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INCOME TAX APPELLATE TRIBUNAL (KOLKATA BENCH)
Rajesh Kumar, AM, Shripadip Kumar Choubey, JM
Sree Bishnu Rice Mill – Appellant
Versus
ACIT, Circle-2 – Respondent
| Table of Content |
|---|
| 1. appeal against disallowance under section 40a(3) (Para 1 , 2) |
| 2. cash payments to agents for paddy procurement covered by rule 6dd(e)(k) (Para 3 , 6) |
| 3. ao's partial acceptance not erroneous; no s.263 jurisdiction (Para 4 , 5) |
| 4. payments through mediators exempt under rule 6dd for agricultural produce (Para 7) |
| 5. assessee's appeal allowed; addition deleted (Para 8) |
ORDER
Per Rajesh Kumar, AM:
This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 26.09.2025 for the AY 2014-15.
2. The issue raised by the assessee in ground no.1 is against the confirmation of addition of ₹14,08,50,854/- as made by the ld. AO u/s 40A(3) of the Act on account of cash payments exceeding to ₹20,000/- to farmers against the purchase of paddy under the wrong understanding of facts that payments were made to the suppliers and not to the cultivators inspite of the admitted fact that the mediators purchased paddy on behalf of the assessee and were reimbursed in cash by the assessee. The other ground nos. 2 and 3 are in support of ground no.1.
3. The facts in brief are that the assessee is engage
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