Form 6R Issued Under Mandi Laws Holds Evidentiary Value, Court Rejects Revenue's Appeal
In a significant decision, the Allahabad High Court has dismissed the appeal filed by the Principal Commissioner of Income Tax (PCIT) against Ankur Mittal, affirming the genuineness of cash purchases made by the assessee and upheld by statutory Form 6R. The Division Bench, comprising Justices Saumitra Dayal Singh and Swarupama Chaturvedi, delivered the judgment on 13th July 2026, maintaining the order of the Income Tax Appellate Tribunal (ITAT) that supported Mittal's claims.
The case arose from the revenue's challenge to the ITAT's decision that cash purchases documented by Form 6R were sufficient for the assessee, a food grain trader, to claim benefits under Rule 6DD of the Income Tax Rules, 1962. The PCIT had previously directed a fresh assessment, requiring additional certificates from the Agriculture Produce Marketing Committee (APMC) to validate the transactions. However, the assessee did not produce these non-statutory certificates, nor did the revenue acquire them.
The High Court emphasized that Form 6R, issued under the Mandi laws, is statutory proof and cannot be disregarded without prima facie evidence questioning its genuineness. The Court also noted that any negligence by Mandi Samiti officials in maintaining records should not be held against the assessee, reinforcing the statutory compliance of the transactions.
The Court further clarified that the revenue's failure to challenge the second assessment order or seek revision on the non-certification of Form 6R weakened their case. The judgment underscored that the purchases were documented, and no doubt was cast on the sales turnover of the assessee, thereby invalidating the revenue's contention.
This decision highlights the evidentiary value of statutory documents in tax assessments and the limitations on revenue authorities to demand non-statutory compliance without substantiated doubt.
Bottom line:-
Income Tax Act, 1961 Section 40A(3) Form 6R issued under Mandi laws has ample evidentiary value and cannot be disregarded in assessing cash purchases made from farmers for agricultural produce, especially when statutory compliance is evident and sales turnover is not doubted.
Statutory provision(s): Income Tax Act, 1961 Sections 263, 40A(3), 69C, Rule 6DD of Income Tax Rules, 1962, Uttar Pradesh Krishi Utpadan Mandi Adhiniyam, 1964 Section 26
Principal Commissioner of Income Tax v. Ankur Mittal, (Allahabad)(DB) : Law Finder Doc id # 2947379
