DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. MIRHA EXPORTS PRIVATE LIMITED, DELHI

PER BENCH :

The above captioned ten appeals by the assessee and five appeals by the Revenue are preferred against order of the ld.

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. Commissioner of Income Tax (Appeals)–24, New Delhi dated 11.08.2025 under section 250 of the Act arising from the assessment order dated 20.07.2024, passed by the Assessing Officer, DCIT, Central Circle – 8, New Delhi under section 147 read with section 143(3) of the Income Tax Act, 1961 (‘the Act’) concerning Assessment Years 2014-15, 2015- 16, 2016-17, 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23 & 2023-24 (for assessee’s appeal), 2013-14, 2014-15, 2017-18, 2018-19 & 2020-21 (for Revenue’s appeal) respectively. 2. Since the underlying facts are common in the asssessee’s as well as Revenue’s appeals and pertain to same assessee, they were heard together and are disposed of by this common order for the sake of convenience and brevity. 3. In ITA No. 5795-5898/DEL/2025 (Assessee's Appeal) for A.Y. 2014-15 to A.Y.2017-18 and in ITA No. 8131,8132-8133/DEL/2025 (Department's Appeal) for A.Y. 2013-14; 2014-15 & Α.Υ.2017-18, at the outset the ld counsel of the assessee submitted that there was a search conducted on the assessee on 21/01/2023 i.e., in previous year A.Y. 2022-23 relevant to A.Y. 2023-24. Accordingly, the 10 years which can be taken up for assessment (subject to compliance to provisions of the Act) would be from A.Y. 2014-15 to A.Y. 2023-24. 4. It is therefore, the say of the ld AR that, the appeal of the Revenue for AY 2013-14 in ITA 8131/Del/2025 is barred by limitation Page 2 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. as beyond 10 years and therefore would not be sustainable in law. The ld AR relied on the decision Hon'ble Delhi High Court in the case of PCIT v. Ojjus Medicare Pvt. Ltd. 2024 (4)TMI 268 (Del) and Filatex India Ltd. v. DCIT, 2023(9) TMI 1484(Delhi High Court). 5. The ld AR also submitted that for AY 2014-15 to AY 2016-17, the notice u/s 143(2) was issued beyond prescribed time limit. It is stated that the notice u/s 148 was issued on 29.03.2023 and the Return of Income was filed on 13.05.2023. It was thus incumbent upon the AO to issue notice u/s 143(2) by 30.06.2024. The AO however issued notice u/s 143(2) on 19.07.2024 and thus barred by time limitation. The ld AR relied on the hon’ble Delhi High Court decision of Paramount Biotech Industries Ltd (2017) 398 ITR 701 (Del)and the decision of hon’ble Supreme Court in the case of Hotel Blue Moon (2010) 321 ITR 362(SC). 6. On the other hand, the ld DR submitted that there is no requirement of issuance of notice u/s 143(2) in search case as held in the case of Ashok Chadda 20 taxmann.com 387 (Del). 7. The ld AR further submitted that for A.Y. 2014-15; A.Y. 2015-16, Α.Υ. 2016-17 and AY 2017-18, being beyond 6 years from the relevant assessment year, could be taken up for assessment u/s 148 only if income represented is in the form of asset, which has escaped assessment and amounts to or is likely to amount to Rs. 50 Lakh or more in accordance with Fourth proviso to section 153A. It is submitted Page 3 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. that as per proviso to section 149, the case u/s 148 could have been reopened only if such case could have been reopened u/s 153A. As per section 153A the case beyond 6 years, can only be reopened only if the income escaping assessment is represented in the Form of "Asset". The ld AR stated that for A.Y. 2017-18 to A.Y. 2014-15, there is no alleged income escaping assessment represented in the form of 'Asset', therefore the proceedings initiated for A.Y. 2017-18 to A.Y. 2014-15 is bad-in-law and without jurisdiction and relied on the decision of the Hon'ble Delhi High Court in the case of Dinesh Jindal v. ACIT, Central Circle - 20 [2024] 469 ITR 32 (Del) and Smart Chip Pvt. Ltd. vs. ACIT, Central Circle-25, New Delhi, 2025 (5) TMI 216-Delhi High Court. 8. On the other hand, the ld DR stated that cash is an ‘asset’. In rejoinder, the ld AR stated that cash found in search is an ‘asset’ but in the case of the assessee, no cash was found and addition was made on account of unaccounted sales. 9. In ITA No. 5799-5801/DEL/2025 [A.Y. 2018-19 to A.Y. 2020- 21(Assessee's Appeal)] and in ITA No. 8134-8135/DEL/2025 [Α.Υ. 2018-19 and A.Y. 2020-21 (Department Appeals), the ld AR stated that the notice issued u/s 148 is barred by limitation being beyond 3 years and the condition of section 149(1)(b) are not met. It is submitted that notice u/s 148 for the year under consideration i.e. A.Y. 2018-19 to A.Y. 2020-21 has been issued on 28.06.2024 i.e. after Page 4 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. the expiry of 3 years from the end of the relevant assessment year. Further, the provisions of section 149(1) of the Act are not met as there is no income escaping assessment represented in the form of (i) asset, (ii) expenditure in respect of a transaction or in relation to an event or occasion; or (iii) an entry or entries in the books of account, which has escaped assessment amounts to or is likely to amount to fifty lakh rupees or more. The ld AR stated that the AO has made addition on transactions, which according to AO himself, were in respect of unaccounted sales and disallowance of expenses. Such estimated income does not fall in any of the category specified in clause (b) of section 149(1). The ld AR relied on the decision of the Hon'ble Delhi High Court in the case of L-1 Identity Solutions Operating Company Private Limited Versus ACIT, CC-25-2025 (4) TMI 1363 Delhi High Court and the case of M/s ACE Tyres (P) Ltd Hyderabad Vs. ACIT Central Circle 2025 (10) TMI 936 ITAT Hyderabad. 10. For the A.Y. 2021-22 in ITA No. 5803/DEL/2025,(assessee’s appeal), the ld AR submitted that the addition confirmed by CIT(A) applying GP rate of 16.50% is erroneous and in any case highly excessive. Instead of applying GP rate, the CIT(A) should have applied NP rate. Even the GP rate applied by CIT(A) is higher than the GP rate declared by the assessee in the audited books of accounts and ITR Page 5 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. which have been accepted by AO. The GP/NP rate declared by assessee in the books of accounts and ITR for Assessment Year 2021-22 is 7.75% and 0.87% respectively. The ld AR submitted that the CIT(A) should have applied only the NP ratio because as per the seized material itself, there were evidence found of not only the direct expenses (i.e. purchases) but also the indirect expenses such as salary and other expenses. As per the seized material there were evidence found of unaccounted purchases as well as unaccounted indirect expenses including salary and other administrative expenses and expenses as pointed out by CIT(A) in para 5.4.6. and para 5.4.7. Therefore, the Hon'ble CIT(A) should have applied NP rate only. The ld AR relied on the decision of Hon'ble Delhi High Court in the case of Indeo Airways (P.) Ltd Vs. Commissioner of Income Tax [2012] 26 taxmann.com 244. 11. In ITA No. 5803/DEL/2025 (Assessee's Appeal) for A.Y. 2022- 23, the ld AR submitted that as the search u/s 132, in the present case, was conducted on 21.01.2023 i.e. F.Y. 2022-23 relevant to A.Y. 2023-24, therefore, as per the Explanation 2 to section 148, the only permissible statutory course available to AO for initiating the assessment proceedings was to issue notice u/s 148 and to complete the assessment after obtaining prior approval u/s 148B before passing assessment order. In the present case, there has no compliance by the Page 6 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. AO either the provisions of section 148 or the provisions of section 148B of the Act. Therefore, the assessment proceedings initiated and also assessment order passed by the AO is bad-in-law and without jurisdiction. The ld AR placed his reliance on Montage Enterprises Pvt. Ltd. v. DCIT, Central Circle II, Delhi ITA no. 5458/DEL/2025. 12. For Α.Υ. 2023-24 in ITA No. 5804/DEL/2025 (assessee’s appeal), the ld AR submitted that the addition was made by the AO as unexplained cash credit u/s 68 of the Act. The Id. CIT(A) changed the addition from unexplained cash credit to cessation of liability u/s 41(1). It is submitted that there is no cessation of liability as the liabilities of the sundry creditors is duly recorded in the books of accounts and in audited financial statement. The ld AR submitted that the CIT(A) has erred in confirming addition of Rs. 25,19,876/- on account of alleged cessation of liability as against addition made by AO on account of unexplained cash credit. The assessee is duly acknowledging the liabilities and the assessing officer cannot treat the liabilities as having been ceased. The amount was never claimed as deduction in the earlier year. Further the amount has not been written back in the books of account. The assessee company is still admitting its liability. The ld AR relied on CIT v Sugauli Sugar Works (P.) Ltd [1999] 102 Taxman 713 (SC); CIT v Shri Vardhman Overseas Ltd

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ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. 2011(12) TMI 77 - Delhi High Court and CIT v Kesaria Tea Co. Ltd.* [2002] 122 Taxman 91 (SC). 13. The ld AR further submitted that the CIT(A) changed the head of addition without issuing any enhancement notice. The ld AR further contested that the CIT(A) has no power to assess income under new source and relied on the decision in the case of Sardarilal & Co 251 ITR 864 of the hon’ble Delhi High Court. 14. Per contra, the ld DR submitted that since 01.04.2021, the search provisions in the Act has been drastically amended. The ld DR stated that in the instant case, the relevant search year is AY 2023-24 and hence AY 2022-23 to AY 2020-21 falls under 3 years block and therefore there is no requirement of fulfilling the condition of “asset”. For the block period beyond 3 years i.e., AY 2019-20 to AY 2013-14, unaccounted sales in cash is “asset” which is an inclusive definition. For AY 2021-22, the ld DR, on the issue of GP addition, submitted that in the case of the assessee, the sale proceeds of offal and extra organs bye-products which are sold in cash, there is no requirement of granting any benefit of expense as the entire expense on sale of meat of the cattle is already booked by the assessee. In the peculiar facts of the trade of the assessee, expense related to the sale of cattle is already booked and accounted for in the books. It is submitted therefore that the entire sale proceeds itself from the bye-product of Page 8 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd.

the cattle, is income of the assessee and no gross profit addition is

required. For AY 2023-24, the ld DR submitted that liability has ceased

to exist, hence provision of section 41(1) is applicable. It is submitted

that no new source is introduced by the CIT(A) as the trade is same and

the advance is existing in the books since last eight years.

materials on record. We find the following additions have been made

by the AO in various years involved. The assessee as well as the

Department have raised legal grounds as well as on merits. We

accordingly adjudicate on the issues year wise. The AO has made

additions for various years as under:

Mirha Exports Pvt. Ltd. Date of search : - 21.01.2023 A.Y. Asst. Issue Additions Additions Additions Department Assessee Date of issue under made by AO confirmed by deleted by in appeal in appeal of notice u/s section CIT(A) CIT(A) 148 2014-15 147 Unaccounted sale 3,29,38,682 52,70,189 2,76,68,493 Yes Yes 29.03.2023

10% of 84,77,600 of 8,47,760 8,47,760 0 Contractor Mohd. Rizwan 2015-16 147 Unaccounted sale 47,52,438 7,60,390 0 Yes 29.03.2023 10% of 2,04,47,009 20,44,701 20,44,701 0 of Contractor Mohd. Rizwan 2016-17 147 Unaccounted sale 93,59,392 14,97,503 0 Yes 29.03.2023

10% of 1,19,45,526 11,94,553 11,94,553 0 of Contractor Mohd. Rizwan 2017-18 147 Unaccounted sale 2,41,37,052 38,61,928 2,02,75,124 Yes Yes 28.06.2024 5% of 53,65,989 2,68,299 2,68,299 0 2018-19 147 Unaccounted sale 4,15,15,934 66,42,549 3,48,73,385 Yes Yes 28.06.2024 5% of 37,14,770 1,85,739 1,85,739 0 6.32% of 1,75,65,310 11,10,128 11,10,128 0

2019-20 147 Unaccounted sale 4,83,504 Yes 28.06.2024 5% of 53,65,989 5,58,003 2020-21 147 Unaccounted sale 3,65,91,389 58,54,622 3,07,36,767 Yes Yes 28.06.2024 5% of 53,65,989 9,57,891 9,57,891 0

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ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. 2021-22 147 Unaccounted sale 1,24,17,538 19,86,806 0 Yes 28.06.2024 5% of 53,65,989 4,11,516 4,11,516 0 2022-23 143 Unaccounted sale 25,32,980 4,05,276 0 Yes NA

2023-24 143 Addition u/s 68 on 25,19,876 25,19,876 0 Yes NA account of Cash Credit Total 17,73,65,771 3,68,61,233 11,35,53,769 16. The assessee’s arguments, in brief, are as under:

A.Y. Assessment Issue under section 2013-14 147 Barred by limitation as beyond 10 years 2014-15 147 No income escaping assessment represented in the form of asset Statutory Notice u/s 143(2) not issued within time limit

2015-16 147 No income escaping assessment represented in the form of asset Statutory Notice u/s 143(2) not issued within time limit 2016-17 147 No income escaping assessment represented in the form of asset Statutory Notice u/s 143(2) not issued within time limit 2017-18 147 No income escaping assessment represented in the form of asset 2018-19 147 No income escaping assessment represented in the form of asset; Expenditure in respect of transaction or in relation to an event or an occasion; or an entry or entries in books of account 2019-20 147 No income escaping assessment represented in the form of asset; Expenditure in respect of transaction or in relation to an event or an occasion; or an entry or entries in books of account 2020-21 147 No income escaping assessment represented in the form of asset; Expenditure in respect of transaction or in relation to an event or an occasion; or an entry or entries in books of account

2022-23 143 Assessment should have been framed u/s 148 and not u/s 143(3) Page 10 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. 17. We now adjudicate the issues raised Assessment year-wise as follows: For AY 2013-14: It is an admitted fact that the search on the assessee took place on 21/01/2023 i.e., in previous year A.Y. 2022-23 relevant to A.Y. 2023- 24. It is also an admitted fact that the notice u/s 148 for AY 2013-14, was issued on 29.03.2023, considering the AY 2013-14 as the relevant assessment year for which the AO has considered that income has escaped assessment as per the provision of section 147 of the Act. Now, as per the provision of section 149(1)(b) of the Act, which prescribes the time limit for issuance of notice u/s 148, no notice shall be issued for the relevant assessment year if three years but not more than ten years have elapsed from the end of relevant assessment year. Accordingly, the 10 years, for which the notice u/s 148 dated 29.03.2023 can be issued, would commence from A.Y. 2023-24 upto AY 2014-15. The 10 years covered under section 148, in accordance with First Proviso to section 149, would be as under: - A.Y. Year 2023-24 1 2022-23 2 2021-22 3 2020-21 4 2019-20 5 2018-19 6 2017-18 7 2016-17 8 Page 11 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. 2015-16 9 2014-15 10

We therefore find that AY 2013-14 is beyond the period of ten years for which notice u/s 148 could have been issued in FY 2022-23. We are therefore of the considered view that the notice u/s 148 of the Act for AY 2013-14 and the consequent reassessment made is barred by limitation, as being beyond 10 years, in accordance with the decision Hon'ble Delhi High Court in the case of PCIT v. Ojjus Medicare Pvt. Ltd. (supra) and therefore would not be sustainable in law. The grounds of Revenue are dismissed. 18. For A.Y. 2014-15; A.Y. 2015-16; Α.Υ. 2016-17 and AY 2017-18 It is undisputed fact that the A.Y. 2014-15; A.Y. 2015-16 and Α.Υ. 2016- 17, the notice u/s 148 of the Act was issued on 29.03.2023 and for AY 2017-18, it was issued on 28.06.2024. It is thus undisputed fact, as reflected in the table above, that the relevant assessment year of AYs 2014-15; A.Y. 2015-16; Α.Υ. 2016-17, and AY 2017-18 are beyond 6 years from the date of issuance of notice u/s 148 of the Act. We agree with the assessee that as per proviso to section 149, the cases A.Y. 2014-15; A.Y. 2015-16 and Α.Υ. 2016-17, and for AY 2017-18, could have been reopened u/s 148 only if such case could have been reopened u/s 153A. As per section 153A the cases beyond 6 years, can be reopened only if the income escaping assessment is represented in Page 12 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. the form of "Asset". We find that for AY 2014-15 to A.Y. 2017-18, the income escaping assessment are not represented in the form of 'Asset'. We agree that cash found in search is considered as an ‘asset’ but in the case of the assessee, no cash was found and addition was made on account of unaccounted sales and estimated expenses. We are therefore, of the considered view, that in absence of income escaping assessment being represented in the form of “asset”, the proceedings initiated for A.Y. 2014-15 to A.Y. 2017-18 is bad-in-law and without jurisdiction in accordance with the decision of the Hon'ble Delhi High Court in the case of Dinesh Jindal v. ACIT, Central Circle - 20 [2024] 469 ITR 32 (Del) and Smart Chip Pvt. Ltd. vs. ACIT, Central Circle- 25, New Delhi, 2025 (5) TMI 216-Delhi High Court. The grounds of Revenue are accordingly dismissed while that of the assessee is allowed. 19. For AY 2018-19 to 2020-21 It is undisputed fact that the A.Y. 2018-19 to AY 2020-21, the notice u/s 148 of the Act was issued on 28.06.2024. The three years for which the notice u/s 148 dated 28.06.2024 can be issued u/s 149(1)(a), without any conditions, are AY 2023-24; AY 2022-23 and 2021-22. Accordingly, the relevant assessment years of A.Y. 2018-19 to AY 2020- 21 are beyond the three year period from the date of issuance of notice u/s 148 of the Act. In such facts and circumstances, the Page 13 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. condition of section 149(1)(b) are to be met which mandates that income escaping assessment be represented in the form of: (i) asset, (ii) expenditure in respect of a transaction or in relation to an event or occasion; or (iii) an entry or entries in the books of account, which has escaped assessment amounts to or is likely to amount to fifty lakh rupees or more. 20. We find that the AO has made the assessments for AY 2018-19 to 2020-21, on account of unaccounted sales and estimation of disallowance of expenses. It remains an uncontroverted fact that there is no income escaping assessment represented in the form of (i) asset, (ii) expenditure in respect of a transaction or in relation to an event or occasion; or (iii) an entry or entries in the books of account, which has escaped assessment amounts to or is likely to amount to fifty lakh rupees or more. We are of the considered view that such income on unaccounted sales and estimated disallowance of expense, does not fall in any of the category specified in clause (b) of section 149(1) and in accordance with the decision of the Hon'ble Delhi High Court in the case of L-1 Identity Solutions Operating Company Private Limited Versus ACIT, CC-25-2025 (4) TMI 1363 Delhi High Court and the case of M/s ACE Tyres (P) Ltd Hyderabad Vs. ACIT Central Circle 2025 (10) TMI 936 ITAT Hyderabad, we hold that the notice u/s 148 issued for

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ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. Α.Υ. 2018-19 and A.Y. 2020-21, are without legal jurisdiction and accordingly the notices u/s 148 and the consequent reassessment orders are quashed. The grounds of Revenue are dismissed while that of assessee is allowed. 21. For the A.Y. 2021-22 We find that in AY 2021-21, the AO has made addition of unaccounted sales which the CIT(A) has restricted to the addition of GP rate of 16.50 % of the sales. The assessee argues that CIT(A) applying GP rate of 16.50% is highly excessive considering the GP rate of 7.75% declared by the assessee in the audited books of accounts and ITR which have been accepted by AO. We find that the assessee could hardly dispute that in the course of search, evidences were found indicating unaccounted purchases as well as unaccounted indirect expenses including salary and other administrative expenses. In such circumstances, in the instant case, it would meet the end of justice, to restrict the G.P. rate to 10% as against 16.50% adopted by the CIT(A). The grounds are partly allowed. 22. For A.Y. 2022-23, We find that for the instant year, it is an admitted fact that the assessment is made under the provisions of section 143(3) of the Act. We also note that a search u/s 132, in the present case, was conducted on 21.01.2023 i.e. F.Y. 2022-23 relevant to A.Y. 2023-24. We Page 15 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. therefore, agree with the assessee that as per the Explanation 2 to section 148, the only permissible statutory course available to AO for initiating the assessment proceedings was to issue notice u/s 148 and to complete the assessment after obtaining prior approval u/s 148B before passing assessment order. Instead, we find that in the impugned AY, the AO has taken recourse to normal provisions of section 143(3) of the Act as against conducting reassessment proceedings u/s 148 of the Act and complying with the provision of section 148B of the Act. We therefore, following the decision of ITAT in Montage Enterprises Pvt. Ltd. v. DCIT, Central Circle II, Delhi (supra), are of the considered view that the assessment proceedings initiated as also assessment order passed by the AO for AY 2022-23, is without jurisdiction and therefore bad-in-law. The grounds are allowed. 23. For Α.Υ. 2023-24 We find for the impugned AY, the AO made an addition as unexplained cash credit u/s 68 of the Act. The Id. CIT(A) changed the addition from unexplained cash credit to cessation of liability u/s 41(1) of the Act. We find that there is no cessation of liability, as the impugned liabilities of Rs. 25,19,876/- of the sundry creditors, duly remain recorded and acknowledged in the books of accounts and in audited financial statement for the said AY. We further find that it remains an uncontroverted fact that the said amount has not been written back in Page 16 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. the books of account nor the assessee has claimed the same as deduction in the earlier year. We therefore agree with assessee that when the assessee has duly acknowledged the liabilities in its books of account, the CIT(A) cannot treat the liabilities as having been ceased. We therefore hold, in accordance with the decisions of the hon’ble Supreme Court in the cases of CIT v Sugauli Sugar Works (P.) Ltd and CIT v Kesaria Tea Co. Ltd (supra) and the hon’ble Delhi High Court in the case of CIT v Shri Vardhman Overseas Ltd (supra), addition u/s 41(1) of the Act is unwarranted and is accordingly directed to be deleted. The grounds are allowed. 24. In the result, the appeals are decided as under: ITA No. 8131; 8132; 8133; 8134; 8135/DEL/2025 (Department's Appeal) are dismissed. ITA No.5795; 5796; 5797; 5798; 5799; 5800; 5801; 5802 and 5804/DEL/2025 (Assessee's Appeal) are allowed. ITA No. 5803/DEL/2025,(assessee’s appeal) is partly allowed.

Order pronounced in the open court on 22.05.2026

Sd/- Sd/- (MADHUMITA ROY) (NAVEEN CHANDRA) JUDICIAL MEMBER ACCOUNTANT MEMBER Date:- 22.05.2026 Priti Yadav, Sr. Ps* Copy forwarded to: 1. Appellant 2. Respondent Page 17 of 19

ITA Nos. 5795-5804 & 8131-8135/Del/2025 Mirha Exports Pvt Ltd. 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI

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