DCIT, CIRCLE - 19(1), DELHI vs. RAMAYNA ISPAT PVT. LTD., DELHI
In the result, the appeal of the assessee and Revenue are dismissed
ITA 4147/DEL/2024[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19
Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalramayna Ispat Private Limited, Dcit, A-48, 1St Floor, Wazirpur Circle-19(1), Industrial Area, Delhi-110052. Vs. New Delhi. Pan-Aaccr7382R (Appellant) (Respondent) Dcit, Ramayna Ispat Private Limited, A-48, 1St Floor, Wazirpur Circle-19(1), New Delhi. Vs. Industrial Area, Delhi-110052. Pan-Aaccr7382R (Appellant) (Respondent) Assessee By Shri Maneesh Upneja, Ca, Shri Baldev Raj, Ca & Ms. Sanju Kumari, Adv. Department By Shri Khitesh Gupta, Sr. Dr Date Of Hearing 27/11/2025 Date Of Pronouncement 27/11/2025 O R D E R Per Manish Agarwal, Am: These Cross Appeals Are Filed By The Assessee & Revenue Against The Order Of Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Ld. Cit(A)] Dated 11.07.2024 U/S 250 Of The Income Tax Act, 1961 (“The Act” In Short) For Assessment Year 2018-19. Ramayna Ispat Pvt. Ltd. Vs. Ito 2. Brief Facts Of The Case Are That The Assessee Is A Private Ltd. Company Engaged In The Business Of Manufacturing, Processing, Forging, Casting Mixing Of Various Kinds Of Steel, Carbon Settle, Mild Steel, Stainless Steel, High Speed Steel & Bright Steel Etc. The Return Of Income Was Revised On 28.10.2018 At An Income Of Rs.1,00,96,587/-. The Case Of The Assessee Was Reopened U/S 148 For The Reason That Assessee Has Taken Accommodation Entries Of Bogus Purchases & After Considering The Submissions Made, Ao Had Made The Addition Of Rs.5,78,99,593/- U/S 69C Of The Act Towards Unexplained Expenditure On Account Of Bogus Purchase & Further Invoked The Provisions Of Section 115Bbe Of The Act. The Ao Further Made An Addition Of Rs.3,14,795/- By Estimating The Net Profit Declared By The Assessee. Besides This Further Disallowance Of Rs.9,37,608/- Was Made Out Of Freight Expenses And, Accordingly, The Total Income Of The Assessee Was Assessed At Rs.6,87,83,788/-.
Section 115BSection 147Section 148Section 250Section 690Section 69C
section 148 of the Act by the Ld. AO even when inter alia the notice u/s 148 was issued: a. By the Jurisdictional Assessing Officer and not by the Faceless Assessing Officer as envisaged in the Act: b. Without implementation of mind by the Ld. AO and only
Ramayna Ispat Pvt. Ltd. vs. ITO on the basis of information