FLINT POWER TOOLS (P) LTD,GURUGRAM vs. ACIT , CENTRAL CIRCLE-1, FARIDABAD

ITA 5642/DEL/2024Status: DisposedITAT Delhi27 October 2025AY 2019-207 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the initiation of proceedings under Section 147 by the Assessing Officer was contrary to Section 151A of the Act. This was based on binding precedents from the Punjab & Haryana High Court in the assessee's own case for earlier assessment years.

What were the facts?

A search and seizure operation led to the reopening of the assessee's case for AY 2019-20. The Assessing Officer made additions of Rs. 36,03,436/- and Rs. 3,436/-. The CIT(A) upheld these additions.

What were the issues?

Whether the initiation of reassessment proceedings under Section 147 by the Assessing Officer was valid, considering the provisions of Section 151A and previous High Court judgments. Whether disallowances for salary and employee PF contribution were justified.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 151A,Section 37,Section 36(1)(v)(a),Section 2(24)(x),Section 234B,Section 234C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH “B”: NEW DELHI

Before: SHRI S RIFAUR RAHMAN & SHRI VIMAL KUMAR

For Appellant: Shri Lalit Mohan, CA & Shri Ankit
For Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Hearing: 20.08.2025Pronounced: 27.10.2025

PER VIMAL KUMAR, JUDICIAL MEMBER:

The appeal filed by the assessee is against order dated 11.11.2024 of Learned Commissioner of Income-Tax (Appeals)-3, Gurgaon (hereinafter referred as “the Ld. CIT(A)”) under Section 250(6) of the Income Tax Act, 1961 ( hereinafter referred as “the Act”) arising out of assessment order dated 27.02.2024 of the Learned Assessing Officer/Assistant Commissioner of Income Tax, Central Circle, Faridabad (hereinafter referred as “Ld. AO") under Section 147 the Act for assessment year 2019-20. 2. Brief facts of case are that a search & seizure operation under Section 132 of the Act was conducted on 10

The order continues below.

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