P P INDUSTRIES,GUWAHATI vs. THE INCOME TAX OFFICER, WARD - 1(2), GUWAHATI, GUWAHATI

ITA 44/GTY/2026Status: DisposedITAT Guwahati05 June 2026AY 2019-207 pages
AI SummaryPartly Allowed

What were the facts?

The assessee, a partnership firm, did not file its return of income. The Assessing Officer initiated reassessment proceedings due to unverified foreign remittances and discovered the assessee was operating with multiple PANs. Additions were made for suppressed business income and unexplained foreign remittance expenditure.

What did the Tribunal hold?

The Tribunal held that the addition for unexplained foreign remittance expenditure was not justified as the remittance was made as per books of account and not from unexplained sources. It also found that additions related to another PAN were wrongly made in the assessee's hands.

What were the issues?

Whether the reassessment proceedings were validly initiated and whether the additions made for foreign remittances and unrelated transactions were justified.

Which sections of the Income-tax Act were involved?

Section 147A,Section 148,Section 148A,Section 69C,Section 115BBE,Section 28

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, GUWAHATI ‘DB’ BENCH AT KOLKATA

Before: SHRI SONJOY SARMA & SHRI RAKESH MISHRA

PER RAKESH MISHRA, ACCOUNTANT MEMBER:

This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals)-NFAC, Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2019-20 dated 20.11.2025. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal:

"

1.

That the ld. Commissioner of Income Tax (Appeals), NFAC erred in facts as well as in law in not holding that Notice U/s. 148A(b) dated 10.02.2023, Order U/s. 148A(d) and Notice U/s. 148 of the Income Tax Act, 1961 dated 31.03.2022 having been issued by the I.T.O., Ward 1(2), Guwah

The order continues below.

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