2026 (7) TMI 1089

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....ndent : Shri Praveen Das Chowdhury, Sr. DR ORDER PER RAJESH KUMAR, ACCOUNTANT MEMBER: This appeal preferred by the assessee is against the order of the Learned Addl./Jt. Commissioner of Income Tax (Appeals),National Faceless Appeal Centre, Delhi, (hereinafter referred to as the "Ld. JCIT(A)"], dated 28.11.2025 for the Assessment Year (AY) 2021-22. 2. At the time of hearing, the learned....

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....of the Income-tax Act, 1961 (In short, 'the Act'). The Assessing Officer, Central Processing Centre (In short, 'the AO, CPC') disallowed the employes PF and ESI by making addition of Rs.80,17,726/- u/s 36(1)(va) of the Act. 4. The assessee challenged the said order before the Ld. CIT(A), which was also dismissed by Ld. CIT(A). 5. We have heard rival submissions and perused the materials avai....

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....-20, order dated 26.02.2026, wherein the similar issue decided in favour of the assessee. 5. The Learned Senior Departmental Representative (Ld. Sr. DR), on the other hand, relied on the order of authorities below. 6. We have heard rival submissions and perused the materials available on record. Undisputed facts are that, the assessee is a tea growing and manufacturing company and the income....

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.... this order is reproduced below: "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 manufacturing company and therefore, the income has to be assessed as per Rule 8 of the IT Rules, which provides that 60% of the income has to be treated as agricultural income which is exempt and only taxable....