(Central)-1 v. NRA Iron & Steel (P) Ltd.

103 Taxmann.com 48Supreme Court of India2019#76 most cited

What is (Central)-1 v. NRA Iron & Steel (P) Ltd. authority for?

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

696

judgments rely on this decision, according to BharatTax’s citation analysis of 371,507 Indian tax judgments — from 2011 to 2026.

Also referred to as

NRA Iron & Steel · (Central)-1 v. NRA Iron & Steel · Section 68 · cash credit · share capital · share application money · unexplained loan · onus of proof · creditworthiness · genuineness of transaction · paper company · shell company · accommodation entries

Sections most often in play

Section 68Section 143(3)Section 147Section 10(38)Section 148Section 69CSection 131Section 133(6)

Issues it is cited on

price riggingbogus share capitalbogus long term capital gainonus of proofpenny stockpaper companypreponderance of probabilitycreditworthiness of the creditorsection 10(38)bogus ltcgshell companysource of source

Judgments citing (Central)-1 v. NRA Iron & Steel (P) Ltd.

Principal Commissioner of Income Tax 2 Kolkata vs. Karni Infraprojects Private Limited

The appeal is dismissed

ITAT/168/2025HC Calcutta28 Jan 2026

Bench: HON'BLE JUSTICE RAJARSHI BHARADWAJ,HON'BLE JUSTICE UDAY KUMAR

Section 68

…OD 4 ORDER SHEET ITAT/168/2025 IA NO:GA/2/2025 IN THE HIGH COURT AT CALCUTTA SPECIAL JURISDICTION (INCOME TAX) ORIGINAL SIDE PRINCIPAL COMMISSIONER OF INCOME TAX-2, KOLKATA VS KARNI INFRAPROJECTS PRIVATE LIMITED BEFORE: The Hon’ble JUSTICE RAJARSHI BHARADWAJ AND The Hon’ble JUSTICE UDAY KUMAR Date: 28th January, 2026. Appearance: Mr. Aryak Dutt, Adv. Mr. Amit Sharma, Adv. …for the appellant Mr. Avra Mazumder, Adv. Ms. Alisha Das, Adv. Ms. Sreeja Mukherjee, Adv. Ms. Rupomita Ghosh, Adv. …for the respondent The Cour…

Anant Keshav Rajegaonkar, Nashik vs. The Asstt. Commissioner of Income Tax, Central Circle - 2, Nashik

ITA 1252/PUN/2024[2015-16]Status: DisposedITAT Pune28 Jan 2026AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1249 To 1252/Pun/2024 Assessment Years : 2013-14, 2014-15 & 2015-16

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Amol Khairnar
Section 143(3)Section 251(2)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA Nos.1249 to 1252/PUN/2024 Assessment Years : 2013-14, 2014-15, and 2015-16 Anant Keshav Rajegaonkar, Vs. The ACIT, G-3, Crown Commercial Complex, Central Circle-2, Sharanpur Road, Nashik Opp. NMC Rajiv Gandhi Bhavan, Nashik – 422 002 Maharashtra PAN : ACPPR9345E Appellant Respondent Appellant by : Shri Pramod S Shingte Respondent by : Shri Amol Khairnar Date of hearing : 17.12.2025 Date of pronouncement : 28.01.2026 आदेश / ORDER PER DR. MANISH BORAD…

Anant Keshav Rajegaonkar, Nashik vs. The Asstt. Commissioner of Income Tax, Central Circle - 2, Nashik

ITA 1251/PUN/2024[2014-15]Status: DisposedITAT Pune28 Jan 2026AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1249 To 1252/Pun/2024 Assessment Years : 2013-14, 2014-15 & 2015-16

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Amol Khairnar
Section 143(3)Section 251(2)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA Nos.1249 to 1252/PUN/2024 Assessment Years : 2013-14, 2014-15, and 2015-16 Anant Keshav Rajegaonkar, Vs. The ACIT, G-3, Crown Commercial Complex, Central Circle-2, Sharanpur Road, Nashik Opp. NMC Rajiv Gandhi Bhavan, Nashik – 422 002 Maharashtra PAN : ACPPR9345E Appellant Respondent Appellant by : Shri Pramod S Shingte Respondent by : Shri Amol Khairnar Date of hearing : 17.12.2025 Date of pronouncement : 28.01.2026 आदेश / ORDER PER DR. MANISH BORAD…

Anant Keshav Rajegaonkar, Nashik vs. The Asstt. Commissioner of of Income Tax, Central Circle - 2, Nashik

ITA 1250/PUN/2024[2014-15]Status: DisposedITAT Pune28 Jan 2026AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1249 To 1252/Pun/2024 Assessment Years : 2013-14, 2014-15 & 2015-16

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Amol Khairnar
Section 143(3)Section 251(2)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA Nos.1249 to 1252/PUN/2024 Assessment Years : 2013-14, 2014-15, and 2015-16 Anant Keshav Rajegaonkar, Vs. The ACIT, G-3, Crown Commercial Complex, Central Circle-2, Sharanpur Road, Nashik Opp. NMC Rajiv Gandhi Bhavan, Nashik – 422 002 Maharashtra PAN : ACPPR9345E Appellant Respondent Appellant by : Shri Pramod S Shingte Respondent by : Shri Amol Khairnar Date of hearing : 17.12.2025 Date of pronouncement : 28.01.2026 आदेश / ORDER PER DR. MANISH BORAD…

Anant Keshav Rajegaonkar, Nashik vs. The Asstt. Commissioner of Income Tax, Central Circle - 2, Nashik

ITA 1249/PUN/2024[2013-14]Status: DisposedITAT Pune28 Jan 2026AY 2013-14

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1249 To 1252/Pun/2024 Assessment Years : 2013-14, 2014-15 & 2015-16

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Amol Khairnar
Section 143(3)Section 251(2)Section 68

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA Nos.1249 to 1252/PUN/2024 Assessment Years : 2013-14, 2014-15, and 2015-16 Anant Keshav Rajegaonkar, Vs. The ACIT, G-3, Crown Commercial Complex, Central Circle-2, Sharanpur Road, Nashik Opp. NMC Rajiv Gandhi Bhavan, Nashik – 422 002 Maharashtra PAN : ACPPR9345E Appellant Respondent Appellant by : Shri Pramod S Shingte Respondent by : Shri Amol Khairnar Date of hearing : 17.12.2025 Date of pronouncement : 28.01.2026 आदेश / ORDER PER DR. MANISH BORAD…

ACIT CC 7(4), Mumbai vs. Aayush Infotech Private Limited, Mumbai

In the result, the appeal filed by the Revenue stands dismissed

ITA 5915/MUM/2025[2013-14]Status: DisposedITAT Mumbai28 Jan 2026AY 2013-14

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 132Section 133(6)Section 143(3)Section 147Section 68Section 69C

…ly deleted. 8. The Revenue is in appeal before us against the said order. The learned Departmental Representative supported the assessment order and placed reliance on the judgment of the Hon’ble Supreme Court in PCIT v. NRA Iron & Steel (P) Ltd. reported in 412 ITR 161 (SC). Per contra, the learned Authorised Representative for the assessee supported the order of the learned CIT(A) and relied upon the judgments of the Hon’ble Gujarat High Court in PCIT v. Ambe Tradecorp (P) Ltd. [145 taxmann.com 27], PCIT v. Ojas Termale (P) Ltd. [156 taxmann.com 75], PCIT v. Merrygold Gems (P) Ltd. [164 taxmann.com 764], and t…

Khojema Bohra, Indore vs. Income Tax Officer, NFAC, Delhi

In the result, the grounds raised on this issue stands "Dismissed"

ITA 812/IND/2024[2014-2015]Status: DisposedITAT Indore22 Jan 2026AY 2014-2015

Bench: Shri B.M. Biyani & Shri Paresh M Joshikhojema Bohra

Section 115BSection 147Section 250Section 253Section 271(1)(c)Section 68

…been mentioned as one of the beneficiaries. (vi) The legal precedents relied upon are equally counterd by other legal precedents on this subject and the decisive decision of the Hon'ble Apex Court in the case of Pr CIT vs. NRA Iron & Steel P Ltd., reported in 103 Taxmann.com 48 vide its order dated 05.03.02019, even though this decision is rendered in the context of share application money treated as unexplained credit, the loan appearing in the books of the appellant in the instant case also stands on similar set of facts as the credit worthiness of the lender has not been satisfactorily proved. The Court after…

C.R. Investments, Delhi vs. ACIT Circle-28(1), Delhi

Appeal is allowed

ITA 900/DEL/2025[2018-19]Status: DisposedITAT Delhi22 Jan 2026AY 2018-19

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)

Section 147Section 68

…is assessee and the payer group which could warrant the impugned addition under section 68 of the Act going by Sumati Dayal Vs. CIT (1995) 214 ITR 2 | P a g e 801 (SC), CIT Vs. Durga Prasad More (1971) 82 ITR 540 (SC) and PCIT Vs. NRA Iron & Steel Co. (2019) 412 ITR 161 (SC). We further reiterate that the assessee has all along filed its entire detailed evidence which has nowhere been specifically rebutted in both the lower proceedings. We thus find merit in the assessee’s instant sole substantive ground to delete the impugned addition of Rs.40,53,468/- in very terms. All other remaining pleadings between the pa…

JCIT(OSD), Circle 111, Dehradun, Subhash Road vs. M/S Suryanchal Furnitech, Bahadrabad Industrial Area, Haridwar

Appeal is partly allowed

ITA 82/DDN/2025[2017-18]Status: DisposedITAT Dehradun21 Jan 2026AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 82/Ddn/2025 : Asstt. Year: 2017-18 Jcit(Osd), Vs M/S Suryanchal Furnitech, Circle-111, F-104, Bahadrabad Industrial Dehradun-248001 Area, Haridwar-249402 (Appellant) (Respondent) Pan No. Abofs3475L Assessee By : Sh. Himanshu Sharma, Adv. Revenue By : Sh. A. S. Rana, Sr. Dr Date Of Hearing: 15.01.2026 Date Of Pronouncement: 21.01.2026 Order Per Satbeer Singh Godara: This Revenue’S Appeal For Assessment Year 2017-18, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1074074259(1) Dated 05.03.2025, In Proceedings U/S 143(3) Of The Income Tax Act, 1961. 2. Heard Both The Parties At Length. Case File Perused.

For Appellant: Sh. Himanshu Sharma, AdvFor Respondent: Sh. A. S. Rana, Sr. DR
Section 133(6)Section 143(3)Section 68

…spective stands against and in support of the impugned addition. The Revenue quotes various landmark judicial precedent in Sumati Dayal vs. CIT (1995) 214 ITR 801 (SC), CIT Vs. Durga Prasad More (1971) 82 ITR 540 and PCIT vs. NRA Iron & Steel Pvt. Ltd. (2019) 412 ITR 161 that we ought to examine the assessee’s relevant evidence and pleadings herein 10 Suryanchal Furnitech regarding source of its’ impugned cash deposits in light of human probability(ies) after removing all blinkers. Mr. Rana next submits that the assessee herein had deposited the impugned cash during demonetization which was claimed as realized f…

DCIT, Delhi vs. Jmk Jewels Private Limited, Delhi

ITA 4282/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 M/S. Jmk Jewels Pvt. Ltd., Vs. Acit, Shop No. 302, Building New Delhi No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) With Assessment Year: 2017-18 Dcit, Vs. M/S. Jmk Jewels Pvt. Ltd., New Delhi Shop No. 302, Building No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Sh. Rahul Bhardwaj, Adv. Department By Sh. Mahesh Kumar, Cit(Dr), Sh. Rajesh Tiwari, Sr. Dr

Section 115BSection 143(3)Section 44ASection 68

…enue’s foregoing vehement submissions and find no reason to accept neither party’s stand in entirety. We first of all refer Sumati Dayal Vs. CIT (1995) 214 ITR 801 (SC), CIT Vs. Durga Prasad More (1971) 82 ITR 540 (SC) and PCIT Vs. NRA Iron & Steel Co. (2019) 412 ITR 161 (SC) that any evidence filed in the course of income tax proceedings has to be examined in light of human 11 | P a g e ITA No.3609 & 4282/Del/2025 probabilities, after removing all blinkers and that mere submission of documentary evidence does not itself discharge an assessee’s onus to prove genuineness of such cash credits. Learned counsel co…

Jmk Jewels Private Limited, Delhi vs. Assistant Commissioner of Income Tax, Delhi

ITA 3609/DEL/2025[2017-18]Status: DisposedITAT Delhi07 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2017-18 M/S. Jmk Jewels Pvt. Ltd., Vs. Acit, Shop No. 302, Building New Delhi No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) With Assessment Year: 2017-18 Dcit, Vs. M/S. Jmk Jewels Pvt. Ltd., New Delhi Shop No. 302, Building No.2678/1, Diamond Mall, Main Gurudwara Road, Karol Bagh, New Delhi Pan: Aabch6018F (Appellant) (Respondent) Assessee By Sh. Pranshu Singhal, Ca Sh. Rahul Bhardwaj, Adv. Department By Sh. Mahesh Kumar, Cit(Dr), Sh. Rajesh Tiwari, Sr. Dr

Section 115BSection 143(3)Section 44ASection 68

…enue’s foregoing vehement submissions and find no reason to accept neither party’s stand in entirety. We first of all refer Sumati Dayal Vs. CIT (1995) 214 ITR 801 (SC), CIT Vs. Durga Prasad More (1971) 82 ITR 540 (SC) and PCIT Vs. NRA Iron & Steel Co. (2019) 412 ITR 161 (SC) that any evidence filed in the course of income tax proceedings has to be examined in light of human 11 | P a g e ITA No.3609 & 4282/Del/2025 probabilities, after removing all blinkers and that mere submission of documentary evidence does not itself discharge an assessee’s onus to prove genuineness of such cash credits. Learned counsel co…

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, Central Circle 3(3), Kolkata

ITA 931/KOL/2025[2019-2020]Status: DisposedITAT Kolkata02 Jan 2026AY 2019-2020
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

Deputy Commissioner of Income Tax, Central Circle 3(1), Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1591/KOL/2025[2021-22]Status: DisposedITAT Kolkata02 Jan 2026AY 2021-22
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

Deputy Commissioner of Income Tax, Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1561/KOL/2025[2020-21]Status: DisposedITAT Kolkata02 Jan 2026AY 2020-21
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

Deputy Commissioner of Income Tax, Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1560/KOL/2025[2019-20]Status: DisposedITAT Kolkata02 Jan 2026AY 2019-20
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

D.C.I.T., CC - 3(1), Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1541/KOL/2025[2018-19]Status: DisposedITAT Kolkata02 Jan 2026AY 2018-19
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

Deputy Commissioner of Income Tax, Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1515/KOL/2025[2017-18]Status: DisposedITAT Kolkata02 Jan 2026AY 2017-18
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

Deputy Commissioner of Income Tax, Central Circle 3.1, Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1436/KOL/2025[2016-17]Status: DisposedITAT Kolkata02 Jan 2026AY 2016-17
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, Central Circle 3(3), Kolkata

ITA 1198/KOL/2025[2021-2022]Status: DisposedITAT Kolkata02 Jan 2026AY 2021-2022
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, Central Circle 3(3), Kolkata

ITA 1196/KOL/2025[2018-2019]Status: DisposedITAT Kolkata02 Jan 2026AY 2018-2019
Section 132Section 132(1)Section 147Section 148

…oned. The appellant's case was reopened on 10.01.2023, after the date of search, and the CIT(A) upheld the AO'S decision to reopen the assessment due to the deeming fiction set out in Explanation 2 to sec. 148. In Pr. CIT vs. NRA Iron & Steel (P) Ltd., (2020) 11 SCC 312, the Supreme Court held that the Assessing Officer was justified in reopening the assessment subsequent to a search and seizure operation under Section 132. The court analyzed the scope of Explanation 2 to Section 148 and found that the AO had the power to reopen the case based on the deeming fiction set out in the provision. After hearing the riv…