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

ITA 1195/KOL/2025Status: DisposedITAT Kolkata02 January 2026AY 2017-201871 pages
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What did the Tribunal hold?

The Tribunal held that the AO's additions were based on surmises and conjectures without independent verification or providing the assessee with the material relied upon. The AO failed to examine the alleged third parties or provide an opportunity for cross-examination.

What were the facts?

The assessee company's case was re-opened under Section 147 based on a search operation conducted on the 'Agarwal Group' and its associates, including the assessee. The Assessing Officer (AO) made additions based on alleged undisclosed purchases of coal from the 'Anup Majee Group'.

What were the issues?

The primary issues were the validity of the reassessment proceedings initiated under Section 147/148 and the AO's reliance on unverified third-party information for making additions for alleged undisclosed purchases.

Which sections of the Income-tax Act were involved?

Section 147,Section 148

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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 & 13.03.

The order continues below.

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