ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

ITA 424/AHD/2024Status: DisposedITAT Ahmedabad23 December 2025AY 2013-1429 pages
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What did the Tribunal hold?

The Tribunal held that the reopening of assessment was bad in law. The reasons recorded were based on incorrect facts, borrowed satisfaction, and lacked proper application of mind, as the information from the third-party search did not directly correlate with the assessee's transactions.

What were the facts?

The assessee's assessment was reopened based on information from a search on the 'Dishman Group', alleging the assessee received accommodation entries. The Assessing Officer (AO) initially suspected non-genuine commission expenses but later made additions for alleged unexplained unsecured loans.

What were the issues?

The primary issue was the validity of the reassessment proceedings initiated under Section 147/148 of the Income Tax Act, 1961, based on information from a third-party search and seizure.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 69A,Section 153C

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Cases cited in this judgment(5)Show list

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Income Tax Appellate Tribunal, “ A ” BENCH, AHMEDABAD

Before: Shri Sanjay Garg & Shri Narendra Prasad Sinha

For Appellant: Shri S.N. Soparkar, Sr.Advocate
Hearing: 19/11/2025Pronounced: 23/12/2025

Per Sanjay Garg, Judicial Member The above captioned four appeals have been preferred by the assessee against the separate orders passed by the Ld. Commissioner of Income-Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “CIT(A)”] all dated 30.01.2024 u/s. 250 of the Income Tax Act, 1961 ("the Act" for short) in respect of the above assessment years. Since issue raised in all the appeals are ident

The order continues below.

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