DEPUTY COMMISSIONER OF INCOME TAX, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

ITA 1515/KOL/2025Status: DisposedITAT Kolkata02 January 2026AY 2017-1871 pages
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What did the Tribunal hold?

The Tribunal held that the reassessment proceedings were initiated based on invalid notices and that the additions for alleged undisclosed purchases were made on mere surmises and conjectures without independent verification. The Tribunal also found that the addition for bogus purchases from Reeja Trading Private Ltd. was made without proper inquiry.

What were the facts?

The assessee company, engaged in manufacturing and trading of iron and steel products, faced reassessment proceedings initiated under Section 147 based on a search operation. The Assessing Officer (AO) made additions for alleged undisclosed purchases of coal from the 'Anup Majee Group' and bogus purchases from 'Reeja Trading Private Ltd.', relying on seized documents and third-party reports.

What were the issues?

The key issues were the validity of the reassessment proceedings initiated under Section 147 and Section 148, and the validity of additions made for alleged undisclosed and bogus purchases without sufficient independent evidence and verification by the AO.

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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