OM SONS MARKETING PRIVATE LIMITED,FARIDKOT vs. DCIT, CENTRE CIRCLE-2, , LUDHIANA

ITA 49/CHANDI/2025Status: DisposedITAT Chandigarh13 January 2026AY 2022-23Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)44 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that additions based solely on third-party evidence without independent corroboration or opportunity for cross-examination are unsustainable. It also found that the assessment proceedings were vitiated due to non-compliance with mandatory procedural requirements.

What were the facts?

The appeals involved allegations of bogus purchases and additions based on third-party evidence like mobile data and seized hard disks. The assessee contended that purchases were supported by documentary evidence and payments were made through banking channels.

What were the issues?

Whether additions based on third-party evidence and seized data are valid without cross-examination and independent corroboration, and whether assessment proceedings were legally valid.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 148,Section 148B,Section 69C,Section 37(1),Section 251(2)

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Cases cited in this judgment(8)Show list

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Heard together (4 matters)

ITA No.48/CHANDI/2025
ITA No.463/CHANDI/2025
ITA No.49/CHANDI/2025
ITA No.193/CHANDI/2025

Read from the judgment's own cause title. This page is filed under one of them.

1 IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH HYBRID HEARING BEFORE HON’BLE SHRI RAJPAL YADAV, VICE PRESIDENT AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM 1. आयकर अपील सं. / ITA No.48/CHANDI/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/s Malbros International Pvt. Ltd. DCIT बनाम/ Village Mansoorwal Central Circle-2 Tehsil Zira Head Office Ludhiana Vs.

Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./PAN/GIR No. AADCM-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. आयकर अपील सं. / ITA No.463/CHANDI/2025 (िनधा"रण वष" / Assessment Year: 2022-23) DCIT M/s Malbros International Pvt. Ltd. बनाम/ Central Circle-2 Village Mansoorwal Ludhiana Tehsil Zira Head Office Vs.

Old Cantt Road, Faridkot – 151203 "थायीलेखासं./जीआइआरसं./PAN/GIR No. AADCM-7203-R (अपीलाथ"/Appellant) (""थ" / Respondent) : & 3. आयकर अपील सं. / ITA No.49/CHANDI/2025 (िनधा"रण वष" / Assessment Year: 2022-23) M/s Om Sons Marketing Pvt. Ltd. DCIT बनाम/ Quila Chowk, Old Cantt Road, Centre Circle-2 Vs.

Faridkot, Punjab-151203 Ludhiana "थायीलेखासं./जीआइआरसं./PAN/GIR No. AAACO-8962-E (अपीलाथ"/Appellant) : (""थ" / Respondent) & 4. आयकर अपील सं. / ITA No.193/CHANDI/2025 (िनधा"रण वष" / Assessment Year: 2

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