KRISHNA CONCAST PRIVATE LIMITED,RAJKOT vs. THE DCIT/ACIT CIR 1(1), RAJKOT, RAJKOT

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ITA 276/RJT/2026Status: DisposedITAT Rajkot03 August 2026AY 2022-233 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal restored the entire matter to the Assessing Officer for de novo adjudication, allowing the assessee one more opportunity to produce evidence. The Assessing Officer is directed to examine the issues afresh after providing a reasonable opportunity of being heard.

What were the facts?

The assessee declared a total income of Rs. 38,23,993/-, but the Assessing Officer assessed it at Rs. 5,70,17,031/- due to partial details furnished. The CIT(A) partly allowed the appeal, sustaining some additions.

What were the issues?

Whether the assessee was denied adequate opportunity to present its case before the lower authorities and if a fresh opportunity should be granted for de novo adjudication.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 142(1),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. BRR Kumar & Shri Sonjoy Sarma

For Appellant: Ms. Devina Patel, Ld. AR
For Respondent: Shri Ram Tiwari, Ld. CIT(DR)
Hearing: 29/07/2026Pronounced: 03/08/2026

आयकर अपीलीय अिधकरण, राजकोट �यायपीठ, राजकोट। In The Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before Dr. BRR Kumar, Vice President And Shri Sonjoy Sarma, Judicial Member

आयकर अपील सं./ITA No. 276/RJT/2026 [ �नधा�रण वष�/Assessment Year: 2022-23 ] Krishna Concast Private Limited The DCIT/ACIT CIR 1(1), 218-Lotus Arcade, Opp. Automative IT Office, New Aayakar Bhawan, Vs. Mfg. Gondal Road, Rajkot-360002 Vatiaka, Rajkot-360001 Gujarat Gujarat �थायीलेखासं./जीआइआरसं./PAN/GIR No.: AADCK4184H (अपीलाथ�/Appellant) (��यथ�/Respondent) Appellant by : Ms. Devina Patel, Ld. AR Respondent by : Shri Ram Tiwari, Ld. CIT(DR) Date of Hearing : 29/07/2026 Date of Pronouncement : 03/08/2026

:: ORDER :: Per, Shri Sonjoy Sarma, JM: Captioned appeal filed by the assessee, pertaining to Assessment Year (AY) 2022-23, is directed against the order under section 250 of the Income-tax Act, 1961 [hereinafter referred to as ‘the Act’] passed by the National Faceless Appeal Centre [hereinafter referred to as ‘NFAC’], dated 24.12.2025, which in turn arises out of an order passed by assessing officer u/s. 143(3) of the Act, dated 21.03.2024.

ITA No. 276/RJT/2026 Krishna Concast Private Limited 02. Brief facts of the case are that the assessee filed the return of income for the Assessment Year 2022–23 declaring a total income of Rs.38,23,993/-. The case was selected for scrutiny under CASS. Accordingly, notices under sections 143(2) and 142(1) of the Income-tax Act, 1961, along with questionnaires, were issued to the assessee. In response to the statutory notices, the assessee furnished only partial details. Since the Assessing Officer was not satisfied with the explanation and supporting documents furnished, the assessment was completed by making various addition and, accordingly, the Assessing Officer assessed the total income of the assessee at Rs.5,70,17,031/-.

3.

Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. Commissioner of Income-tax (Appeals). The Ld. CIT(A) partly allowed the appeal by granting partial relief while sustaining the remaining additions with certain observations.

4.

Still aggrieved, the assessee is in further appeal before the Tribunal.

5.

At the time of hearing, the Ld. AR submitted that the assessee could not properly substantiate its claims before the lower authorities due to lack of adequate opportunity and, therefore, prayed that one more opportunity be granted to the assessee to produce all relevant books of account and supporting documentary evidence before the Assessing Officer. It was submitted that the assessee shall fully cooperate in the set-aside proceedings.

6.

The Ld. DR, on the other hand, supported the orders of the lower authorities.

7.

We have heard the rival submissions and perused the material available on record. It is evident that although opportunities were afforded to the assessee during the assessment proceedings, the assessee could not furnish the requisite details and

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ITA No. 276/RJT/2026 Krishna Concast Private Limited documentary evidence. Considering the facts and circumstances of the case, and in the interest of substantial justice, we deem it appropriate to restore the entire matter to the file of the Assessing Officer for de novo adjudication. The Assessing Officer shall examine the issues afresh after affording adequate and reasonable opportunity of being heard to the assessee. The assessee is also directed to extend full cooperation by furnishing all relevant books of account and supporting evidence as may be called for. Needless to say, the Assessing Officer shall pass a speaking order in accordance with law after considering the material placed on record.

8.

In the result, the appeal of the assessee is allowed for statistical purposes.

Order pronounced in the open court on this 3rd day of August, 2026.

Sd/- Sd/- [ Dr. BRR Kumar] [ Shri Sonjoy Sarma ] Vice President Judicial Member राजकोट/Rajkot िदनांक/ Date: 03/08/2026 Copy of the order forwarded to : 1. The assessee 2. The Respondent 3. CIT 4. The CIT(A) 5. DR, ITAT, Rajkot 6. Guard File By order //True Copy// Sr. Private Secretary ITAT, Rajkot

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