D.C.I.T., CC - 3(1),, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

ITA 1541/KOL/2025Status: DisposedITAT Kolkata02 January 2026AY 2018-1971 pages
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What did the Tribunal hold?

The Tribunal held that the additions made by the AO were based on surmises and conjectures without independent verification or providing the assessee with relevant material for cross-examination. The re-opening of the assessment and the subsequent additions were found to be legally infirm.

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, and a notice under Section 148 was issued. The Assessing Officer (AO) made additions based on alleged undisclosed purchases of coal.

What were the issues?

The primary issues were the validity of the notice issued under Section 148 for re-opening the assessment and the legality of additions made based on alleged undisclosed purchases without proper verification and opportunity for cross-examination.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 132

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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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