2026 (2) TMI 1446

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.... DR. ORDER PER RAJESH KUMAR, AM: These are appeals preferred by the assessee against the orders of the Commissioner of Income-tax (Appeals), Vadodara (hereinafter referred to as the "Ld. CIT(A)"] dated 20.09.2024 for the AYs 2018-19 & 2019-20. 2. At the outset, we note that the appeals of the assessee are barred by limitation by 349 days. At the time of hearing the counsel of the asses....

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....31.10.2018, declaring total income of Rs.31,30,392/-. The ld. counsel submitted that while processing the return of income u/s 143(1) of the Income-tax Act, 1961,the ld. AO made disallowance u/s 36(1)(va) of the Act which was admittedly not paid before the due date. The counsel submitted that the assessee is a tea manufacturing company and the income has to be assessed by following the Rules 8 of ....

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....cordingly after following the mandate of rule 8 and assess the income in accordance with Rule 8 of Western Conglomerate Ltd.; A.Y. 2018-19 & 2019-20 the IT rules. The ld. DR on the other hand did not oppose the contention of the ld. AR. 4.1. After hearing the rival contentions and perusing the materials available on record, we find that undisputedly the company is a tea growing and manufacturin....