DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3(1),, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

ITA 1591/KOL/2025Status: DisposedITAT Kolkata02 January 2026AY 2021-2271 pages
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What did the Tribunal hold?

The Tribunal held that the AO's additions were based on conjecture and surmises, lacking proper evidence and verification. The AO failed to establish a direct link between the alleged transactions and the assessee, and did not provide sufficient material to support the additions.

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 reopened, and the Assessing Officer (AO) made additions based on alleged undisclosed purchases and cash transactions. The CIT(A) confirmed these additions.

What were the issues?

The primary issues were the validity of the reassessment proceedings initiated under Section 147/148, and the validity of additions made on account of alleged undisclosed purchases and cash transactions without sufficient corroborating evidence.

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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