KUNDAN JEWELLERS PRIVATE LIMITED,GANDHI CHOWK, SADAR BAZAR, MUKTSAR vs. THE INCOME TAX OFFICER, WARD-2(2), MUKTSAR, MUKTSAR

ITA 284/ASR/2025Status: DisposedITAT Amritsar06 April 2026AY 2014-1515 pages
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What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were invalid and void ab initio because the AO initiated them based on incorrect facts and without proper application of mind. The alleged transactions did not belong to the assessee company.

What were the facts?

The assessee, Kundan Jewellers Pvt. Ltd., engaged in goldsmith labor charges, had its assessment reopened based on information suggesting it provided accommodation entries. The Assessing Officer (AO) alleged undisclosed transactions of Rs. 70,09,601/- with Ridhi International.

What were the issues?

Whether the reassessment proceedings initiated based on incorrect facts and without proper application of mind are valid. Whether the addition made on account of alleged accommodation entries is sustainable.

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE,Section 147,Section 148,Section 151,Section 250

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Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR

Before: SH. UDAYAN DASGUPTA & SH. KRINWANT SAHAY

Hearing: 18.02.2026Pronounced: 06.04

Per Udayan Dasgupta, J.M.:

This appeal is filed by the assessee against the order of the ld. CIT (A) NFAC, Delhi dated 20.02.2025 passed u/s 250 of the Income Tax Act, 1961(henceforth the Act) which has emanated from the order of the NFAC, Delhi dated 30.03.2022 passed u/s 147/144B of the Act.

2.

Grounds of appeal taken by the assessee in Form No. 36 are as follows:

2 Assessment Year: 2014-15

“1. That the Ld. CIT(A) NFAC has erred on facts and law, vide order u/s 250 of the Act dt. 20.02.2025, in confirming the addition of Rs. 70,09,601/- U/S 69A r.w.s. 115BBE of the Act, made by the AO vide assessment order u

The order continues below.

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