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

ITA 1198/KOL/2025Status: DisposedITAT Kolkata02 January 2026AY 2021-202271 pages
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What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were initiated based on alleged documents and statements from third parties without independent verification by the AO. The AO's reliance on conjecture and surmises, and the denial of cross-examination, rendered the addition unsustainable.

What were the facts?

The assessee company, engaged in manufacturing and trading of iron and steel products, was subject to a search operation. Subsequently, the case was re-opened under Section 147, leading to additions based on alleged undisclosed purchases of coal.

What were the issues?

The primary issues were the validity of the reassessment proceedings initiated under Section 147/148, and whether additions based on third-party information without independent verification and cross-examination are legally tenable.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 132(1)

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Cases cited in this judgment(8)Show list

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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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