BINOD AUTOMOBILES,ANGUL vs. INCOME TAX OFFICER,ANGUL WARD, ANGUL, ANGUL
In the result appeal of the assessee is allowed
ITA 602/CTK/2025[2013-14]Status: DisposedITAT Cuttack02 Dec 2025AY 2013-14
Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.602/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2013-2014) Binod Automobiles, Vs Ito, Angul Ward, Angul At- Nh 55 Kandsar, Nalco Nagar Dist – Angul-759145 Pan No. :Aalfb 0713 C (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri S.K.Sarangi, Ar राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 02/12/2025 घोषणा की तारीख/Date Of Pronouncement : 02/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 18.09.2025 For The Assessment Year 2013-2014. 2. It Was Submitted By The Ld.Ar That The Assessee Is Dealer In Automobile. There Was A Survey On The Premises Of The Assessee On 05/02/2015. On The Basis Of The Survey The Ddit Had Alleged Suppression In The Investment In The Showroom To An Extent Of Rs.3,10,03,517/-. It Was Submission That The Reasons For Reopening Is At Page 2 Of The Paper Book Which Reads As Follows:-
For Appellant: Shri S.K.Sarangi, ARFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 143Section 147
…9. Further, it is seen that the reasons for reopening of the assessment merely repeats the language of the report of the DDIT (Inv.) without any independent application of mind by the AO. In Sabh Infrastructure Ltd. v. Asst. Commissioner of Income Tax [2017] 398 ITR 198 (Delhi), the Delhi High Court in similar circumstances set aside the re-assessment order. In paragraph-15 of the said decision, it has been observed that assessment proceedings, especially those under Section 143 (3) of the Act "have to be accorded sanctity and any reopening of the same has to be on a strong and sound legal basis." It was further…
