KIMPLAS PIPING SYSTEMS PRIVATE LIMTIED ,MUMBAI vs. DCIT, 15(1)(2), MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER

ITA No. 8533/MUM/2025 (Assessment Year : 2020-21) Kimplas Piping Systems Pvt. Ltd, B-20 MIDC Amand Nashik – 422010 ............... Appellant PAN: AAACG3404H v/s Deputy Commissioner of Income Tax – 15(1)(2), ……………… Respondent Aayakar Bhawan, Mumbai- 400020 Assessee by : Shri Nishit Gandhi Revenue by : Shri Hemanshu Joshi, Sr. DR

Date of Hearing – 29/04/2026 Date of Order - /05/2026

O R D E R PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeal against the impugned order dated 15.10.2025, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”], for the assessment year 2020-21.

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addition made to total income of the Appellant of unreconciled difference of reported figure with books of accounts. 1.2 The CIT(A) failed to appreciate that the no details of reported figure have been furnished by AO to Appellant. 1.3 The Appellant prays that on the facts and circumstances of the cases and in law the addition made to total income not justifiable. General 2. The Assessing officer has erred in computing gross total income of Rs. 12,31,01,391/- as against the income return by appellate of Rs. 11,65,47,682/- on account of variation in data furnished by Directorate General of Foreign Trade (DGFT) with financial data of the appellant without providing details of it. 3. Without Prejudice to the above: i. The Id. CIT (A) erred in confirming the action of A.O. on the ground that no reconciliation have been furnished by Appellant of reported figure by DGFT with audited accounts whereby the A.O. treated the amount of Rs. 65,53,709/- to income as per income filed. ii. While doing so, the Id. CIT (A) filed to appreciate that: (i) No details have been furnished by AO of the amount reported by DGFT during the course of assessment for reconciling the difference. (ii) Appellant has provided completed details of Export & Import as per audited accounts. iii. It is submitted that in the facts and the circumstances of the case, and in law, no such addition was called for."

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assessment proceedings, upon the perusal of the quantum of imports reported by the DGFT, it was observed that the assessee’s total imports for the year under consideration were Rs. 31,67,05,414/-. However, as per the return of income filed by the assessee, the assessee has declared purchases amounting to Rs.9,64,24,137/-. Accordingly, the assessee was asked to explain the reasons for the difference and reconcile the same. In response, the assessee submitted that in the return of income, the purchases only pertained to finished goods. However, the total imports are of Rs.31,69,17,677/-. Accordingly, the assessee filed a reconciliation statement, wherein there was a difference of Rs.2,12,263/- in the quantum of imports as reported by the DGFT and that of the assessee. It was further submitted that due to the unavailability of the details provided by the DGFT with the assessee, the variation cannot be exactly verified. Accordingly, the Assessing Officer (“AO”), vide order dated 27.09.2022, passed under section 143(3) read with section 144B of the Act, made an addition of Rs. 2,12,263/-, being the difference which remained unreconciled to the total income of the assessee. Similarly, as there was a difference of Rs. 63,41,446/- in the quantum of exports as reported by the DGFT and as reported by the assessee in its return of income, the AO made an addition of Rs. 63,41,446/- to the total income of the assessee.

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imports and exports as per the information received from the DGFT and as declared by the assessee in its return of income. We find that during the assessment proceedings, it was noticed that as per the details provided by the DGFT, the assessee has made an import to an extent of Rs. 31,67,05,414/-. However, as per its return of income, the assessee has disclosed purchases of Rs.9,64,24,137/-. We further find that pursuant to the opportunity being granted to the assessee, the assessee filed a final reconciliation of the total import figure of Rs.31,69,17,677/- as against figure of Rs.31,67,05,414/- reported by the DGFT. Therefore, an addition of Rs. 2,12,263/- was made on the basis of unreconciled imports. Thus, it is evident that the assessee, to a large extent, was able to reconcile with the information as provided by the DGFT. Similarly, in respect of exports, the addition was only restricted to Rs.63,41,446/-.

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as well as imports as received from the DGFT to the assessee on the basis of which the impugned addition was made in the hands of the assessee. Upon receipt of the aforesaid information/details, we also direct the assessee to reconcile the data pertaining to imports and exports made during the year. Needless to mention, no order shall be passed without affording reasonable and adequate opportunity of hearing to the assessee. As the issue is restored to the file of the Jurisdictional AO for consideration afresh, all the contentions of the assessee are kept open. With the above directions, the impugned order is set aside, and the grounds raised by the assessee are allowed for statistical purposes.

Sd/- Sd/- VIKRAM SINGH YADAV SANDEEP SINGH KARHAIL ACCOUNTANT MEMBER JUDICIAL MEMBER MUMBAI, DATED: 06/05/2026 Prabhat

Copy of the order forwarded to: (1) The Assessee; (2) The Revenue; (3) The PCIT / CIT (Judicial); (4) The DR, ITAT, Mumbai; and (5) Guard file. By Order Assistant Registrar ITAT, Mumbai.