DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), KOLKATA, KOLKATA vs. MAAN STEEL & POWER LIMITED , KOLKATA

ITA 1096/KOL/2025Status: DisposedITAT Kolkata25 June 2026AY 2018-1920 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were invalid as the AO initiated them based on material from a third-party search without following proper procedures. Furthermore, the AO failed to provide the assessee an opportunity to cross-examine or confront the material gathered, violating principles of natural justice.

What were the facts?

The Assessing Officer (AO) reopened the assessment for AY 2018-19 under Section 147 based on information from a search on a third party (Majee Group). The AO made additions based on alleged cash purchases of coal from the Majee Group, which the assessee denied. The CIT(A) partly allowed the appeal.

What were the issues?

Whether reassessment proceedings initiated based on third-party search material are valid, and whether the AO's failure to provide an opportunity for cross-examination violates natural justice principles.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 142(2),Section 142(3),Section 68

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH, KOLKATA

Before: SHRI RAJESH KUMAR, AM & SHRI PRADIP KUMAR CHOUBEY, JM

For Appellant: Shri AK Tulsyan&
For Respondent: Shri Md. Gayasuddin Ansari, DR
Hearing: 10.06.2026Pronounced: 25.06.2026

Per Rajesh Kumar, AM:

These are the cross appeals preferred by the revenue and the assessee against the orders of the Commissioner of Income-tax ITA Nos. 1167, 2354,1096, 26

The order continues below.

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