J N TAYAL STEELS PRIVATE LIMITED,LUDHIANA vs. INCOME TAX OFFICER WARD-2(1), GUWAHATI, GUWAHATI

IN THE INCOME TAX APPELLATE TRIBUNAL – GUWAHATI BENCH VIRTUAL BENCH AT KOLKATA Before Shri Sonjoy Sarma, Judicial Member and Shri Rakesh Mishra, Accountant Member ITA No.163/GTY/2025 Assessment Year: 2016-17 J N Tayal Steels Private Limited…………………………………….…..Appellant C/o-VV Bhalla & Co., SCF-39, Rishi Nagar, Main Market, Ludhiana Punjab-141001 [PAN: AACCJ2365E] vs. ITO, Ward-2(1), Guwahati….……………………………..……...…..…..Respondent Assam-781005 Appearances by: Shri Pankaj Bhalla, AR, appeared on behalf of the Appellant. Shri Santosh Kumar Karnani, Addl. CIT, appeared on behalf of the Respondent. Date of concluding the hearing : May 05, 2026 Date of pronouncing the order : May 07, 2026

ORDER Per Sonjoy Sarma, Judicial Member: The present appeal filed by the assessee is directed against the order dated 26.05.2025 passed by the NFAC, Delhi [hereinafter referred to as the ‘Ld. CIT(A)] u/s 250 of the Income Tax Act, 1961 (the ‘Act’) for the assessment year 2016-17. 2. Brief facts of the case are that, assessee filed its return of income for the assessment year 2016-17. Subsequently, the case of the assessee was reopened u/s 147 of the Act. On the basis of information that assessee had made purchases amounting to Rs.32,71,705/- from M/s Sidh Jogi Steel & Agro Industries. Accordingly, notice u/s 148 of the Act was issued. In response, assessee filed return declaring total income of Rs.12,57,110/-. During the course of re-assessment proceedings, notices u/s 143(2) and 142(1) were issued, however, according to the

ITA No.163/GTY/2025 J N Tayal Steels Private Limited Assessing Officer, the assessee failed to furnish satisfactory details and did not adequately substantiate the aforesaid purchase transactions. Consequently, the Ld. Assessing Officer completed the assessment u/s 147 r.w.s. 144B of the Act, and made an addition of Rs.32,71,705/- to the total income of the assessee. The total income of the assessee was assessed at Rs.45,28,815/-. 3. Dissatisfied with the above order, assessee went in appeal before the Ld. CIT(A), where the appeal of the assessee was dismissed and sustained the addition made by the Assessing Officer. 4. Aggrieved by the above order, the assessee is in appeal before this Tribunal. At the time of hearing, the Ld. AR submitted that the re- assessment proceedings are bad in law. It was further contended that the assessee had, in fact, furnished supporting documents in respect of the impugned purchase before the Assessing Officer, however, such documents were not properly considered while passing the assessment order. It was also argued that the authorities below failed to appreciate the evidences on record, and therefore, the matter requires fresh examination. 5. On the other hand, the Ld. DR supported the decision of the authorities below. 6. We have heard the rival submissions, and perused the material available on record. In the present case of the assessee, the appeal pertains to addition of Rs. 32,71,705/- on account of purchases made from one M/s Sidh Jogi Steel & Agro Industries. The contention of the assessee is that necessary supporting documents were furnished during the course of assessment proceedings, however, the same were overlooked by the Assessing Officer while passing the order, and also not duly appreciated by the Ld. CIT(A). Considering the submissions of the assessee, and in the interest of justice, we are of the view that the issue

ITA No.163/GTY/2025 J N Tayal Steels Private Limited requires re-examination at the level of the Assessing Officer. Accordingly, the matter is restored to the file of the Assessing Officer for fresh adjudication, after considering evidences furnished by the assessee. The assessee is also directed to cooperate and furnish all necessary details as may be called for by the Assessing Officer. 7. In the result, appeal of the assessee is allowed for statistical purposes.

Kolkata, the 07th May, 2026.

Sd/- Sd/- [Rakesh Mishra] [Sonjoy Sarma] Accountant Member Judicial Member Dated: 07.05.2026. DP, PS Copy of the order forwarded to: 1. Appellant - 2. Respondent - 3. CIT(A)- 4. CIT- , 5. CIT(DR),

//True copy// By order Assistant Registrar, Kolkata Benches