REEM BROKING PVT. LTD.,AHMEDABAD vs. THE ITO, WARD-1(3)(1) PREVIOUSLY ACIT, CIRCLE-1(3), AHMEDABAD

ITA 323/AHD/2026Status: DisposedITAT Ahmedabad25 September 2026AY 2012-1314 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the unsecured loans were not sham transactions, as the assessee had provided details of receipts and repayments. Consequently, the reassessment was barred by limitation as the assessee had not failed to disclose material facts.

What were the facts?

The assessee's assessment was reopened after 4 years based on information about accommodation entries provided by a third party. The Assessing Officer added the alleged unsecured loans as income, and the CIT(A) confirmed this addition.

What were the issues?

Whether the reassessment proceedings were validly initiated after the expiry of four years from the end of the relevant assessment year, and whether the unsecured loans were genuine.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AHMEDABAD “A” BENCH

Before: Shri Narendra Prasad Sinha & Shri Tapas Ram Misra

For Appellant: Shri Kunal Shangvi, AR
For Respondent: Shri Amit Pratap Singh, Sr. D.R

PER TAPAS RAM MISRA, JUDICIAL MEMBER:

The present appeal has been filed by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (hereinafter referred to as “CIT(A)”), dated 31.12.2025 passed under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2012-13. 2. The assessee has raised the following grounds of appeal: [1] The Ld. CIT(A) NFAC. Delhi was grievously erred in considering the notice u/s 148 which is illegal and time barred.

I.T.A No. 323 /Ahd/2026 A.Y. 2012-13 Reem Broking

The order continues below.

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