“Section 133(6)”

Samrat Finvestors Private Limited, Kolkata vs. DCIT, Cent. Cir. 4(2), Kolkata

In the result, the appeals of the assessee are partly allowed

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

effect of the statement of AKA also took note of the fact that the notices which were issued by the Assessing Officer under section 133(6) to the lenders where duly acknowledged and all the lenders confirmed the loan transactions by filing the documents which were placed before the tribunal ... assessee and also cross verified by the assessing officer pursuant to the enquiry conducted in response to the notices issued under Section 133(6) of the Act. 020. Further the assessee has duly furnished all the evidences necessary to substantiate creditworthiness and genuineness of transactions, i.e., for discharge of onus

Samrat Finvestors Private Limited, Kolkata vs. DCIT, Cent. Cir. 4(2), Kolkata

In the result, the appeals of the assessee are partly allowed

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

effect of the statement of AKA also took note of the fact that the notices which were issued by the Assessing Officer under section 133(6) to the lenders where duly acknowledged and all the lenders confirmed the loan transactions by filing the documents which were placed before the tribunal ... assessee and also cross verified by the assessing officer pursuant to the enquiry conducted in response to the notices issued under Section 133(6) of the Act. 020. Further the assessee has duly furnished all the evidences necessary to substantiate creditworthiness and genuineness of transactions, i.e., for discharge of onus

Samrat Finvestors Private Limited, Kolkata vs. DCIT, Cent. Cir. 4(2), Kolkata

In the result, the appeals of the assessee are partly allowed

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

effect of the statement of AKA also took note of the fact that the notices which were issued by the Assessing Officer under section 133(6) to the lenders where duly acknowledged and all the lenders confirmed the loan transactions by filing the documents which were placed before the tribunal ... assessee and also cross verified by the assessing officer pursuant to the enquiry conducted in response to the notices issued under Section 133(6) of the Act. 020. Further the assessee has duly furnished all the evidences necessary to substantiate creditworthiness and genuineness of transactions, i.e., for discharge of onus

Samrat Finvestors Private Limited, Kolkata vs. ITO, Ward 5(2) (Now DCIT, Cent.Cir. 4(2)), Kolkata

In the result, the appeals of the assessee are partly allowed

Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm

effect of the statement of AKA also took note of the fact that the notices which were issued by the Assessing Officer under section 133(6) to the lenders where duly acknowledged and all the lenders confirmed the loan transactions by filing the documents which were placed before the tribunal ... assessee and also cross verified by the assessing officer pursuant to the enquiry conducted in response to the notices issued under Section 133(6) of the Act. 020. Further the assessee has duly furnished all the evidences necessary to substantiate creditworthiness and genuineness of transactions, i.e., for discharge of onus

Sollfege Electronics Private Limited (Presently Known As Sollfege Electronics Limited), Kolkata vs. ITO, Ward 8(2), Kolkata

In the result, appeal of the assessee is allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.1012/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2018-2019) Sollfege Electronics Private Vs Ito Ward 8(2), Limited P-7, Chowringhee Square, (Presently Known As Sollfege Kolkata-700069, West Bengal Electronics Limited) 3, Pretoria Street, 2Nd Floor, Chandrakunj Building, Kolkata-700071, West Bengal Pan No. :Aaecd4463B (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Shri Soumitra Choudhury & Shri Pranabesh Sarkar, Advocates रधजस्व की ओर से /Revenue By : Shri S.B.Chakraborthy, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 27/08/2025 घोषणा की तारीख/Date Of Pronouncement : 16/10/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Assessee Against The Order Dated 22.03.2025, Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2018-2019. 2. At The Time Of Hearing, Ld.Counsel For The Assessee Pressed The Grounds No.8, 9, 10 & 11, Which Are Raised By The Assessee To Challenge The Confirmation Of Addition By The Ld. Cit(A) Of Rs.60.00 Lakhs Made By The Assessing Officer U/S.68 Of The Act As Unexplained Cash Credit. 3. Facts In Brief Are That The Assessee Is Engaged In The Business Of Trading Of Electronics Audio, Video Etc. The Assessee Filed Its Return Of Income U/S.139(1) Of The Act On 06.10.2018 Declaring Total Income At Rs.95,23,889/-. The Notice U/S.148A(B) Of The Act Was Issued By The Assessing

details such as copy of ledger account, bank statements, income tax returns, balance sheet etc. It was also recorded that notice under Section 133(6) of the Act was issued to the said parties which were duly responded by them. The identity of the parties could not be, therefore disputed

DCIT, CC-2(3), Kolkata, Aayakar Bhawan Poorva vs. Maxcab Industries Pvt. Ltd., Kolkata

In the result, the appeal of the Revenue is dismissed

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Dcit, Central Circle-2(3), Maxcab Industries Pvt. Ltd. 4Th Floor, 110 Shantipally, 67/C, Balaram Dey Street, E.M. Bypass, Vs. West Bengal-700006 West Bengal-700107 (Appellant) (Respondent) Pan No. Aancm1997Q Assessee By : Shri Soumitra Choudhury & Ms. Nandini Surekh, Shri Pranabesh Sarkar, Ars Revenue By : Praveen Kishore, Dr Date Of Hearing: 04.09.2025 Date Of Pronouncement: 16.10.2025

Kumar Saffar that assessee had taken accommodation entries in the form of loans. The learned AO also noted that the notices issued under Section 133(6) of the Act could not be served by the inspector as they were not existing in their addresses. The learned AO also noted that ... before the appellate authority. The learned CIT (A) also noted the loan creditors have also duly complied with the notices issued under section 133(6) of the Act by the AO and hence deleted the addition. 05. After hearing the rival contentions and perusing the materials available on record

Assistant Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. Somani Services Private Limited, Kolkata

Bench: the Hon'ble ITAT, Kolkata.

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER I.T.A

Assistant Commissioner of Income Tax, Central Circle-1(2), Kolkata vs. Somani Services Private Limited, Kolkata

Bench: the Hon'ble ITAT, Kolkata.

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER I.T.A

Pravesh Kumar Jaiswal, Kolkata vs. I.T.O., Ward - 62(1), Kolkata

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarmapravesh Kumar Jaiswal Vs Ito, Ward-62(1), Kolkata 245A, Apc Road, Manicktalla, Kol-700006. Pan No. :Acspj9691A (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri Sunil Surana, Ar राज"व क" ओर से /Revenue By : Shri P. N. Barnwal, Cir- Dr सुनवाई क" तार"ख / Date Of Hearing : 08/10/2025 घोषणा क" तार"ख/Date Of Pronouncement : 16/10/2025 आदेश / O R D E R Per Sonjoy Sarma, Jm : This Appeal By The Assessee Arises Against The Order Of The Learned Commissioner Of Income Tax (Appeals), Kolkata, Whereby The Action Of The Assessing Officer In Making An Addition Of ₹1,27,38,506/- Under Section 69C Read With Section 115Bbe Of The Income-Tax Act, 1961 Was Confirmed. 2. Brief Facts Of The Case Are That The Case Of The Assessee Was Selected For Scrutiny As It Was Noticed That The Assessee Had Made Substantial Purchases From Certain Suppliers Who Were Either Non- Filers Of Income Tax Returns, Filed Returns With Abnormally Low Turnover, Or Whose Gst Registrations Were Either Cancelled Or Suo Motu Suspended As Per Adg (Gst) Data. Based On This Information, The Assessing Officer Formed A View That There Was A Possibility Of The Assessee Booking Bogus Or Inflated Purchase Expenses To Reduce Taxable Profit & Accordingly, Scrutiny Proceedings Were Initiated By Issue Of Statutory Notices. During

proceedings were initiated by issue of statutory notices. During 2 Pravesh Kumar Jaiswal the course of assessment, the Assessing Officer issued notices under section 133(6) to the suppliers seeking verification of the transactions. However, many of such notices remained unserved or unresponded, and in some cases, the e-mails ... channels, and other supporting evidence during the assessment proceedings. The Assessing Officer relied solely on the non-response of suppliers to notices under section 133(6) and the alleged cancellation of their GST registrations, which are factors beyond the control of the assessee. Once sales have been accepted, the corresponding