M/S. MAAN STEEL & POWER LIMITED,KOLKATA vs. ACIT, CENTRAL CIRCLE 1(2),, KOLKATA

ITA 2354/KOL/2025Status: DisposedITAT Kolkata25 June 2026AY 2019-202020 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reassessment proceedings under Section 147 were invalid as they were initiated based on material from a third-party search without proper procedures. Furthermore, the AO violated principles of natural justice by not confronting the assessee with the gathered material and not providing an opportunity for cross-examination.

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 under Section 147 based on third-party search material are valid, and whether the AO violated principles of natural justice by not confronting the assessee with evidence.

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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