INCOME TAX OFFICER-2(1), BHILAI, BHILAI vs. SATKAR CATERERS PVT. LTD, DURG

ITA 739/RPR/2025Status: DisposedITAT Raipur05 August 2026AY 2015-1623 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the notice issued under Section 148 was invalid because the approval was obtained from the PCIT instead of the Joint Commissioner, as required by the old Section 151(2). Consequently, the reassessment proceedings were quashed.

What were the facts?

The Revenue appealed against the CIT(A)'s order deleting additions made on account of bogus billing. The Assessing Officer had reopened the assessment based on information from a search and seizure operation, alleging the assessee availed accommodation entries from a shell company.

What were the issues?

The primary issue was the validity of the reassessment proceedings due to improper sanction for issuing the notice under Section 148. Another issue was whether the additions made by the AO were based on sufficient evidence.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151,Section 69A,Section 69C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR

Before: JUSTICE (RETD.) SHRI C. V. BHADANG & SHRI R. K. PANDA

For Appellant: Shri Sunil Kumar Agrawal, CA
For Respondent: Shri Piyush Tripathi, Sr.DR

PER R.K. PANDA, VP:

This appeal filed by the Revenue is directed against the order dated 26.09.2025 of the Ld. CIT(A)-3, Bhopal relating to assessment year 2015-16. 2. Facts of the case, in brief, are that the assessee filed its return of income on 05.11.2015 declaring total income of Rs.9,44,260/-. Information was available with the department that the assessee M/s. Satkar Caterers Pvt Ltd.had availed bogus billing accommodation entry through shell company i.e. Silverlake Marketing Pvt. Ltd. to the tune of Rs.1,79,13,000/-. During the course of search and seizure operation carried out against Kolkata based group – Bathwal group and one entry operator Shri Ajit Kumar Jindal it

The order continues below.

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