ASIA PACIFIC RESOURCES PRIVATE LIMITED,AHMEDABAD vs. INCOME TAX OFFICER WARD 1(1)(3), AHMEDABAD

ITA 477/AHD/2026Status: DisposedITAT Ahmedabad24 September 2026AY 2013-1412 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the reopening of the assessment was invalid because there was a disconnect between the information received, the reasons recorded, and the actual addition made. The reassessment order was quashed as the foundation for reopening was not established.

What were the facts?

The Assessing Officer (AO) reopened the assessee's assessment based on information that the assessee received Rs. 6 crores as an accommodation entry from M/s. Ayan Trading Co. However, the AO ultimately made additions for alleged bogus purchases from M/s. SP Trading Company and M/s. Patel Trading Company.

What were the issues?

Whether the reopening of assessment was valid when the addition made was on account of different transactions than those forming the basis of the reasons recorded.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, AHMEDABAD

Before: SHRI SANJAY GARG & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri Tarun Jamnadas Ghia, CA
For Respondent: Shri Kiran Unavekar, CIT-DR & Amit Pratap Singh, Sr
Hearing: 15.07.2026Pronounced: 24.09.2026

PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER:

These two appeals are filed by the Assessee against separate orders of National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “CIT(A)”] both dated 23.12.2025 for the Assessment Years (A.Y.) 2013-14 and 2014-15 in the proceeding u/s 147 r.w.s. 144B of the Income Tax Act [hereinafter referred as “the Act”]. As the issues involved in these two appeals are identical, both the matters were heard together and are being disposed of vide this common order for the sake of convenience. We w

The order continues below.

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