RAJKESARI METALS PVT LTD,UDAIPUR vs. ACIT, CIRCLE-2, UDAIPUR, UDAIPUR

ITA 776/JODH/2025Status: DisposedITAT Jodhpur21 May 2026AY 2020-2115 pages
AI SummaryAllowed

What were the facts?

The assessee, an EOU, had a stock variation noted by the customs department, leading to a reopening of assessment by the AO. The AO made an addition of Rs. 52,00,000/- on account of alleged unaccounted excess stock.

What did the Tribunal hold?

The Tribunal held that the AO failed to disprove the documentary evidence furnished by the assessee and made the addition based on suspicion, which is not sustainable. The CIT(A)'s order was also found to be perverse.

What were the issues?

Whether the addition on account of alleged excess stock, based on customs information and without rejecting books of account, is sustainable. Whether the CIT(A) erred in passing an ex-parte order without adequate opportunity.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 148,Section 148A(b),Section 148A(d),Section 110,Section 125,Section 234A,Section 234B,Section 234C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JODHPUR BENCH, JODHPUR

For Appellant: Shri Shrawan Gupta, Advocate
For Respondent: Shri Anil Kumar Bharadwaj

DR. MITHA LAL MEENA, A.M.: This appeal is filed by assessee against the order of National Faceless Appeal Centre (NFAC) Delhi [hereinafter referred to as the NFAC/CIT(A)] dated 05.08.2025 with respect to the assessment year 2020-21. 2. The appellant assessee has raised the following grounds of appeal:-

1.

Ground3. The Id. AO has grossly erred in law as well as on the facts of the case in charging interest u/s 234A,234B and 234C,. 1 The appellant totally

2 denies it liability of charging of any such interest. The interest, so charged, being contrary to the provisions of law and facts, may kindly be deleted in full.

2.

Ground4. The appellant prays your honour indulgences to add, 2 amend OR alter of OR any of the grounds of th

The order continues below.

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