VIRU TEXTILE MILLS PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-4(1)(1), AHMEDABAD
What did the Tribunal hold?
The Tribunal held that the assessment order for AY 2020-21 was bad in law as it should have been passed under Section 153C, not Section 143(3). For AYs 2013-14 and 2014-15, the Tribunal's findings on merits from the lead case would apply.
What were the facts?
The assessee company received accommodation entries totaling Rs. 92,84,166/- from three entities, which were treated as unexplained cash credits. Additionally, a significant difference was noted between bank credits and declared turnover, leading to further additions.
What were the issues?
The primary issues were the validity of reopening under Section 147/148A, the denial of cross-examination, and whether the assessment for AY 2020-21 should have been under Section 153C instead of Section 143(3).
Which sections of the Income-tax Act were involved?
Section 68,Section 115BBE,Section 143(1),Section 147,Section 148,Section 143(2),Section 142(1),Section 133(6),Section 143(3),Section 144B,Section 148A,Section 151,Section 153C
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, “ A ” BENCH, AHMEDABAD
Before: Shri Sanjay Garg & Annapurna Gupta
Heard together (3 matters)
Read from the judgment's own cause title. This page is filed under one of them.
आदेश की )ितिलिप अ-ेिषत/Copy of the Order forwarded to : 1. अपीलाथ( / The Appellant 2. )/थ( / The Respondent. 3. संबंिधत आयकर आयु0 / Concerned CIT 4. आयकर आयु0 अपील ( ) / The CIT(A)- (NFAC), Delhi 5. िवभागीय )ितिनिध आयकर अपीलीय अिधकरण अहमदाबाद/DR,ITAT, Ahmedabad. , , 6. गाड� फाईल / Guard file.
आदेशानुसार/ BY ORDER, स$ािपत %ित //True Copy// सहायक पंजीकार (Asstt. Registrar) आयकर अपीलीय अिधकरण, ITAT, Ahmedabad
Date of dictation (dictation on computer of H-JM’s : 23.4.2026 computer) 2. Date on which the typed draft is placed before the : 24.4.2026 Dictating Member. 3. Date on which the approved draft comes to the Sr.P.S./P.S : 4. Date on which the fair order is placed before the Dictating : Member for pronouncement. 5. Date on which fair order placed before Other Member : 6. Date on which the fair order comes back to the : 27.4.26 Sr.P.S./P.S. 7. Date on which the file goes to the Bench Clerk. : 27.4.26 8. Date on which the file goes to the Head Clerk. : 9. The date on which the file goes to the Assistant Registrar : for signature on the order. 10. Date of Despatch of the Order :
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