HAMMER PLUS JEWELLERY PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER, MUMBAI

ITA 2450/MUM/2026Status: DisposedITAT Mumbai14 October 2026AY 2018-20193 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the addition of Rs.7,23,18,982/- under section 69A of the Income Tax Act, 1961, was justified. The reasoning was based on the assessee's failure to provide any material to rebut the adverse findings of the Assessing Officer, which were affirmed by the Commissioner (NFAC). Specifically, the assessee did not reconcile the discrepancies between bank credits and trade receivables, nor did it furnish any cogent documentary evidence to substantiate its claims or counter the observation that it might be a paper company. The Tribunal found no infirmity in the decision of the Commissioner (NFAC) in sustaining the addition. The ratio decidendi is that in the absence of satisfactory explanation and documentary evidence to justify unexplained credits in bank accounts, the addition made by the Assessing Officer under section 69A, and sustained by the appellate authority, will be upheld. The operative direction is that the appeal filed by the assessee is dismissed. The assessee was granted liberty to seek recall of the ex parte order upon demonstrating sufficient cause for non-appearance.

What were the facts?

The assessee, Hammer Plus Jewellery Pvt. Ltd., filed an appeal against the order dated 02.01.2026 passed by the National Faceless Appeal Centre (NFAC), Delhi, for Assessment Year 2018-19. The appeal was decided ex parte as the assessee neither appeared nor filed an adjournment application, despite prior notices remaining uncomplied with. The Assessing Officer had made an addition of Rs.7,23,18,982/- under section 69A of the Income Tax Act, 1961, towards unexplained credits in the assessee's bank account, based on an assessment order dated 23.03.2024 passed under section 147 read with section 144B of the Act. The NFAC sustained this addition.

What were the issues?

1. Whether the addition of Rs.7,23,18,982/- under section 69A of the Income Tax Act, 1961, towards unexplained credits in the assessee's bank account is justified, considering the assessee's failure to reconcile discrepancies between bank credits and trade receivables, and to provide third-party evidence for genuine business activities, as observed by the Assessing Officer and affirmed by the Commissioner (NFAC)? Assessee's contentions: The judgment records no specific contentions from the assessee, as the appeal was decided ex parte. The assessee's non-appearance suggests a lack of engagement with the proceedings or the grounds of appeal. Revenue's contentions: The revenue, through its Senior Departmental Representative (SR DR), implicitly supported the findings of the lower authorities. The Assessing Officer's order, sustained by the NFAC, was based on the assessee's inconsistent submissions with its balance sheet, unreconciled discrepancies between bank credits and trade receivables, and the absence of third-party evidence to substantiate genuine business activities or rebut the observation of the assessee being a paper company.

Which sections of the Income-tax Act were involved?

Section 69A,Section 147,Section 144B,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “E”, MUMBAI

Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI BIJAYANANDA PRUSETH

For Respondent: Smt. Sujatha Iyyanger, SR DR
Pronounced: 14.10.2026

Per : Narender Kumar Choudhry, Judicial Member

This appeal has been preferred by the Assessee against the order dated 02.01.2026, impugned herein, passed by the Ld. National Faceless Appeal Centre (NFAC), Delhi (in short ‘Ld. Commissioner’), under section 250 of the Income Tax Act, 1961 (in short ‘the Act’), for A.Y. 2018-19. 2. Despite sending notice for today's hearing, neither did the Assessee appear nor was any adjournment application filed. The record further reveals that notices issued on earlier occasions 2

through RP

The order continues below.

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