SANJIB ZENAT ISPAT,BATHINDA vs. INCOME TAX OFFICER WARD-1(4), BATHINDA

ITA 121/ASR/2025Status: DisposedITAT Amritsar17 June 2026AY 2018-1911 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition could not be sustained solely on the verbal statement of the seller without any tangible material like invoices or transport documents to prove actual delivery. The Tribunal also noted a violation of natural justice due to the lack of cross-examination opportunity for the assessee.

What were the facts?

The assessee's return of income was 'Nil'. Information was received alleging the assessee made cash purchases of Rs. 7,94,680/- from Futuristic Metal Trading Pvt. Ltd. The AO initiated reassessment proceedings based on this information, leading to an addition of the said amount as unexplained expenditure.

What were the issues?

Whether reassessment proceedings were validly initiated on borrowed satisfaction and whether the addition was sustainable without independent inquiry and opportunity for cross-examination.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 69C,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: SH. MANOJ KUMAR AGGARWAL & SH. UDAYAN DAS GUPTA

Hearing: 07.04.2026Pronounced: 17.06.2026

Per: Udayan Dasgupta, JM: This appeal is filed by the assessee against the order of ld. CIT(A), NFAC, Delhi, passed u/s 250 of the IT Act, 1961, dated 16.01.2025, which has emanated from the order of the AO, NFAC, Delhi, passed u/s 147 r.w.s. 144 of the Act, dated 15.02.2023. 2. The grounds of appeal taken in Form 36 are as follows:

“1. That on the facts and in the circumstances of the case and in law, the learned CIT(A), NFAC, Delhi erred in upholding the re-assessment proceedings and re-assessment order. Assessment Year: 2018-19 2

2.

That on the facts and in the circumstances of the case and in law, the learned CIT(A), NFAC. Delhi has erred in upholding re- opening

The order continues below.

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