M/S. SHAKAMBHARI ISPAT & POWER LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), , KOLKATA

ITA 1194/KOL/2025Status: DisposedITAT Kolkata02 January 2026AY 2016-201771 pages
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What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were initiated based on an invalid notice under Section 148. The additions made by the Assessing Officer were found to be based on conjecture and surmises without proper verification or opportunity for cross-examination.

What were the facts?

The assessee company, engaged in manufacturing and trading of iron and steel products, was subjected to a search operation. Subsequently, the case was reopened under Section 147, leading to reassessment proceedings and additions based on alleged undisclosed purchases.

What were the issues?

The primary issues were the validity of the reassessment notice and proceedings, and whether the additions made for alleged undisclosed purchases were substantiated by evidence and due process.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 132(1)

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Income Tax Appellate Tribunal, “D” BENCH, KOLKATA

Before: SHRI RAJESH KUMAR & SHRI PRADIP KUMAR CHOUBEY

For Appellant: Shri S. Jhajharia, FCA, Shri Sanat Kumar Raha, CIT-DR
For Respondent: Shri Sanat Kumar Raha, CIT-DR
Hearing: 29/10/2025Pronounced: 02/01/2026

Per Bench: These are the cross appeals filed by the assessee and revenue against the separate orders passed by the CIT(A), Kolkata-21, 28.02.2025

The order continues below.

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