SHIVALIK ENGINEERING INDUSTRIES LIMITED,RAIPUR vs. DY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), RAIPUR, RAIPUR

ITA 716/RPR/2025Status: DisposedITAT Raipur28 July 2026AY 2017-1819 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the assessee had fulfilled its onus by providing invoices, lorry receipts, bank statements, and ledger accounts to prove sales to Fast Deal Corporation, Delhi. The Tribunal also found that the investigation report lacked specific information linking the assessee to the alleged bogus transactions and that the notice under Section 148A(b) was issued without tangible material.

What were the facts?

The assessee's assessment was reopened based on information from the Investigation Wing regarding alleged entry providers. The Assessing Officer (AO) made an addition under Section 68, and the CIT(A) confirmed it. The assessee argued that they had provided sufficient documentation to prove genuine sales to Fast Deal Corporation, Delhi, and denied any transaction with Fast Deal Corporation, Kolkata.

What were the issues?

Whether the reopening of assessment was valid and whether the addition made under Section 68 was justified based on the evidence provided by the assessee.

Which sections of the Income-tax Act were involved?

Section 68,Section 147,Section 144B,Section 148,Section 148A,Section 151

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH “DB”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL Dr. DIPAK P. RIPOTE

For Appellant: Shri Praveen Khandelwal, CA, Shri Praveen Goyal, CA
For Respondent: Shri CH. Rajeswara Reddy, DR
Hearing: 14.05.2026Pronounced: 28.07.2026

PER DR. DIPAK P. RIPOTE, AM:

This is an appeal filed by the assessee against the order of the Commissioner of Income Tax (Appeals) [CIT(A)], National Faceless Appeal Centre (NFAC), Delhi, passed under section 250 of the Income Tax Act, 1961 (‘the Act’) for the Assessment Year (AY) 2017-18 on 10.09.2025 emanating from assessment order under section 147 r.w.s 144B of the Act, dated 24.03.2025. 2 Shivalik Engineering Industries Limited, Raipur

2.

The assessee has raised following grounds of appeal:

“1. That on the facts and in the circumstances of

The order continues below.

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