VALUEADDED FUTURISTIC MANAGEMENT PVT. LTD.,KOLKATA vs. DCIT/ACIT CIRCLE - 1, RANCHI

ITA 355/RAN/2025Status: DisposedITAT Ranchi05 June 2026AY 2014-20157 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reopening of the assessment beyond four years was not justified as the assessee denied the transaction and the Assessing Officer failed to prove any failure on the assessee's part to disclose material facts. The addition made by the Assessing Officer was deleted.

What were the facts?

The assessee's case was reopened under Section 147 based on information that it had transactions with a shell company. The Assessing Officer added ₹70.00 lacs as unexplained credits, which was confirmed by the CIT(A). The assessee denied any such transaction and argued the reopening was beyond four years and invalid.

What were the issues?

Whether the reopening of assessment under Section 147 beyond four years is valid when the assessee denies the transaction and there is no failure to disclose material facts. Whether the addition under Section 68 is justified in the absence of a valid reopening.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 148,Section 68

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: SHRI SONJOY SARMA & SHRI RATNESH NANDAN SAHAY

For Appellant: Shri Devesh Poddar, A.R
For Respondent: Shri Kailash Gautam, Sr.DR
Hearing: 22/05/2026Pronounced: 05/06/2026

PER: RATNESH NANDAN SAHAY, A.M.

1.

This appeal by the assessee is directed against the order of the National Faceless Appeal Centre (NFAC), Delhi [in short, the ld. CIT(A)] dated 28/08/2025 for the Assessment Year (AY) 2014-15. The assessee has raised following grounds of appeal:

"

1.

That the reassessment order passed under section 147 read with section 143(3) of the Income-tax Act, 1961 is bad in law, without juri iction and void ab initio, and hence liable to be quashed.

2.

That the learned Assessing Officer erred in reopening the completed assessment without there being any failure on the part of

The order continues below.

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