SHRI PARASRAM COMMODITIES PVT LTD.,DELHI vs. DCIT, CIRCLE-23(1), DELHI

ITA 4630/DEL/2025Status: DisposedITAT Delhi18 March 2026AY 2012-13Bench: the NFAC who vide order dated 27-09-2024 dismissed the appeal of the assessee because the assessee did not appeared before the Ld. NFAC. Being aggrieved the order of the Ld. NFAC the assessee is in appeal before the Tribunal.6 pages
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What did the Tribunal hold?

The Tribunal held that when a case is reopened on specific reasons, the Assessing Officer cannot make additions on entirely different grounds. Since the addition was made on the issue of sham share transactions, which was not the basis for reopening, the reassessment was held to be invalid. The Tribunal allowed the appeal based on this legal ground.

What were the facts?

The assessee's case was reopened under section 148 based on information that Shri Ravinder Kumar Aggarwal, who received ₹1 crore from the assessee, could not substantiate the source of funds for his property purchase. However, the Assessing Officer made an addition of ₹66,77,951 on account of accommodation entry related to sham share transactions instead of the alleged loan to Shri Aggarwal.

What were the issues?

Whether the reassessment proceedings are valid when the addition made by the AO is on grounds different from the reasons recorded for reopening the assessment.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 143(3),Section 68

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Income Tax Appellate Tribunal, DELHI BENCH “B”NEWDELHI

Before: SHRI SUDHIR KUMAR & SHRI MANISH AGARWAL

For Respondent: Ms. Kanchan Garg, Sr.DR
Hearing: 11.02.2026

PER SUDHIR KUMAR JM: The assessee preferred the appeal, challenging the order dated 27- 09-2024 passed by National Faceless Appeal Centre Delhi (in short Ld. NFAC) arising out from the assessment order dated 31-12-2019 passed by the Assessing Officer for A.Y. 2012-13 under the section 143(3)/147 of the Income Tax Act, 1961(In short “the Act”). 1

2.

The brief facts of the case are that the assessee has filed the return of income on 26-09-2012 declaring total income of Rs.3,78,75,070/- The case of the assessee was selected for scrutiny and assessment proceedings u/s 143(3) of the Act was completed on 30-03-2014 at an income of Rs.3,82,02,890/-. S

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