ACIT-19(3), MUMBAI, MUMBAI vs. RED EXIM DIAMOND LLP, MUMBAI

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ITA 7989/MUM/2025Status: DisposedITAT Mumbai24 April 2026AY 2014-1521 pages

In favour of the Revenue: the Revenue's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the notice under Section 148 and the consequent assessment order were barred by time limitation, rendering them void ab initio. Consequently, the Revenue's appeal was dismissed as infructuous.

What were the facts?

The assessee, Red Exim Diamond LLP, engaged in export/import of diamonds, had its case reopened under Section 147 based on information from an investigation wing regarding accommodation entries. The Assessing Officer (AO) made significant additions for alleged bogus purchases.

What were the issues?

The primary issue was the validity of the reassessment proceedings initiated under Section 147 due to alleged time-barred notice under Section 148 and the subsequent additions made for bogus purchases.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 69C,Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI PRABHASH SHANKAR

For Appellant: Shri Bhupendra Shah, AR
For Respondent: Shri AnnavaramKosuri, Sr.AR
Hearing: 23.03.2026Pronounced: 24.04.2026

आदेश की प्रतितलतप अग्रेतिि/Copy of the Order forwarded to : 1. अपीलार्थी / The Appellant 2. प्रत्यर्थी / The Respondent. 3. आयकर आयुक्त / CIT 4. विभागीय प्रविवनवि, आयकर अपीलीय अविकरण DR, ITAT, Mumbai 5. गार्ड फाईल / Guard file.

सत्यावपि प्रवि //True Copy// आदेशानुसार/ BY ORDER,

उप/सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपीलीय अतधकरण/ ITAT, Bench, Mumbai.

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