AMIT KUMAR,DELHI vs. INCOME TAX OFFICER, WARD 1(1), GUWAHATI, INCOME TAS OFFICER

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Assessing Officer issued a reopening notice against assessee on ground that an information was received from DIT (Investigation) that during a search conducted in case of a group of companies, it was found that assessee had obtained accommodation entries in nature of unsecured loans through two 8 I.T.A. Nos. 32 & 33/GTY/2024 Amit Kumar paper/shell companies, impugned reopening notice issued against

M/S. SEEMA HOLDING PVT. LTD.,KOLKATA vs. A.C.I.T., CIRCLE -1, GUWAHATI

In the result, appeal of the assessee in ITA No

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 67/Gty/2023 Assessment Year: 2014-15 M/S. Seema Holding Pvt. Ltd. I.T.O. Ward-15(2), Kolkata Vs [Now, Acit, Central Circle-1, 89, Muktaram Babu Street Guwahati] Kolkata - 700007 [Pan : Aadcs5209H] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

reopening is beyond 4 years from the original assessment u/s 143(3) of the Act. As, we have discussed and decided the legal issue in favour of the assessee and the re-assessment order u/s 147 r.w.s. 144 of the Act, itself has attained nullity, the grounds on merits are only academic in nature and the same are not dealt

M/S. SEEMA HOLDING PVT. LTD.,KOLKATA vs. A.C.I.T., CIRCLE -1, GUWAHATI

In the result, appeal of the assessee in ITA No

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 67/Gty/2023 Assessment Year: 2014-15 M/S. Seema Holding Pvt. Ltd. I.T.O. Ward-15(2), Kolkata Vs [Now, Acit, Central Circle-1, 89, Muktaram Babu Street Guwahati] Kolkata - 700007 [Pan : Aadcs5209H] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

reopening is beyond 4 years from the original assessment u/s 143(3) of the Act. As, we have discussed and decided the legal issue in favour of the assessee and the re-assessment order u/s 147 r.w.s. 144 of the Act, itself has attained nullity, the grounds on merits are only academic in nature and the same are not dealt

M/S. SEEMA HOLDING PVT. LTD.,KOLKATA vs. A.C.I.T., CIRCLE -1, GUWAHATI

In the result, appeal of the assessee in ITA No

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 67/Gty/2023 Assessment Year: 2014-15 M/S. Seema Holding Pvt. Ltd. I.T.O. Ward-15(2), Kolkata Vs [Now, Acit, Central Circle-1, 89, Muktaram Babu Street Guwahati] Kolkata - 700007 [Pan : Aadcs5209H] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

reopening is beyond 4 years from the original assessment u/s 143(3) of the Act. As, we have discussed and decided the legal issue in favour of the assessee and the re-assessment order u/s 147 r.w.s. 144 of the Act, itself has attained nullity, the grounds on merits are only academic in nature and the same are not dealt

SHRI LIKHA SAAYA,NIRJILI vs. INCOME TAX OFFICER, WARD- NORTH LAKHIMPUR., LAKHIMPUR.

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

Bench: S/Shriand Rajesh Kumarand Manmohan Dasita Nos.49 & 50/Gty/2021 Assessment Years : 2010-11 & 2011-12 Shri Likha Saaya S/O. Shri Likha Vs. Ito, Ward-North, Lakhimpur Heli, P-Sector, P.O. Nirjuli, Borah Complex, D.K.Road, North District Papumpare, Arunachal Lakhimpur, Lakhimpur, Assam- Pradesh-791109 787001 Pan/Gir No. (Appellant) .. ( Respondent) Assessee By : Sarala Agarwal. Ar Revenue By : Shri Kausik Ray, Jcit

purchase of some properties, which did not materialise and, therefore, the cash was deposited back into the bank accounts of the assessee. Therefore, once the sources of cash deposits are explained to be out of withdrawals of cash from the bank account of the assessee, then same cannot be added to the income of the assessee as unexplained money

SHRI LIKHA SAAYA,NIRJILI vs. INCOME TAX OFFICER, WARD- NORTH LAKHIMPUR., LAKHIMPUR.

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

Bench: S/Shriand Rajesh Kumarand Manmohan Dasita Nos.49 & 50/Gty/2021 Assessment Years : 2010-11 & 2011-12 Shri Likha Saaya S/O. Shri Likha Vs. Ito, Ward-North, Lakhimpur Heli, P-Sector, P.O. Nirjuli, Borah Complex, D.K.Road, North District Papumpare, Arunachal Lakhimpur, Lakhimpur, Assam- Pradesh-791109 787001 Pan/Gir No. (Appellant) .. ( Respondent) Assessee By : Sarala Agarwal. Ar Revenue By : Shri Kausik Ray, Jcit

purchase of some properties, which did not materialise and, therefore, the cash was deposited back into the bank accounts of the assessee. Therefore, once the sources of cash deposits are explained to be out of withdrawals of cash from the bank account of the assessee, then same cannot be added to the income of the assessee as unexplained money

NISHA RANI,C/O SAHAY ENTERPRISES vs. THE INCOME TAX OFFICER, WARD -1(2), AAYAKAR BHAWAN,

In the result, this appeal of the assessee is partly allowed

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumarnisha Rani, I.T.O., Bedi Market, At Road, Ward-1(2), Vs. Guwahati-781001 (Assam) Guwahati. (Appellant) (Respondent) Pan No. Afjpr 7852 P Assessee By : Shri Vishesh Surana, Fca. Revenue By : Shri Santosh Kumar Karnani, Addl. Cit Date Of Hearing: 09/03/2026 Date Of Pronouncement: 13/03/2026 O R D E R

Assessing Officer under Section 69C of the Income Tax Act, 1961 (in short, the Act) on account of bogus purchases by the assessee. 2 Nisha Rani Vs ITO 3. The facts of the case, in brief, are that the assessee filed return of income declaring total income of ₹ 45,50,680/-. The case of the assessee was reopened

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Manomohan Das & Shri Rakesh Mishra

bogus purchases (liability shown as sundry creditors) as mentioned in the assessment order. The addition was made as the assessee failed to produce any evidence in support of the claim of purchases made and the existence of the sundry creditors could not be proved in spite of having been provided several opportunities. The Ld. CIT(A) also issued direction

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Manomohan Das & Shri Rakesh Mishra

bogus purchases (liability shown as sundry creditors) as mentioned in the assessment order. The addition was made as the assessee failed to produce any evidence in support of the claim of purchases made and the existence of the sundry creditors could not be proved in spite of having been provided several opportunities. The Ld. CIT(A) also issued direction

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Manomohan Das & Shri Rakesh Mishra

bogus purchases (liability shown as sundry creditors) as mentioned in the assessment order. The addition was made as the assessee failed to produce any evidence in support of the claim of purchases made and the existence of the sundry creditors could not be proved in spite of having been provided several opportunities. The Ld. CIT(A) also issued direction

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Manomohan Das & Shri Rakesh Mishra

bogus purchases (liability shown as sundry creditors) as mentioned in the assessment order. The addition was made as the assessee failed to produce any evidence in support of the claim of purchases made and the existence of the sundry creditors could not be proved in spite of having been provided several opportunities. The Ld. CIT(A) also issued direction

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Manomohan Das & Shri Rakesh Mishra

bogus purchases (liability shown as sundry creditors) as mentioned in the assessment order. The addition was made as the assessee failed to produce any evidence in support of the claim of purchases made and the existence of the sundry creditors could not be proved in spite of having been provided several opportunities. The Ld. CIT(A) also issued direction

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Manomohan Das & Shri Rakesh Mishra

bogus purchases (liability shown as sundry creditors) as mentioned in the assessment order. The addition was made as the assessee failed to produce any evidence in support of the claim of purchases made and the existence of the sundry creditors could not be proved in spite of having been provided several opportunities. The Ld. CIT(A) also issued direction

JAYANTA KHAUND,GUWAHATI vs. ACIT CIR-1, GUWAHATI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Manomohan Das & Shri Rakesh Mishra

bogus purchases (liability shown as sundry creditors) as mentioned in the assessment order. The addition was made as the assessee failed to produce any evidence in support of the claim of purchases made and the existence of the sundry creditors could not be proved in spite of having been provided several opportunities. The Ld. CIT(A) also issued direction

INCOME TAX OFFICER, WARD-1, SILCHAR vs. ROHIT KUMAR GULGULIA, SILCHAR

In the result, appeal of the revenue is dismissed

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2011-12

reopening the assessment? • Whether on facts and in the circumstances of the case the Ld.CIT(A) was justified in deciding that the assessment order passed by AO was bad in law because the objections raised by the assessee against initiation of proceedings u/s 147 were not disposed of by the AO by any speaking order in writing as required under

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. MEENAKSHI BAMALWA SONI, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

reopen and/or assess the return with respect to six preceding years; however, there must be some incriminating material available with the Assessing Officer with respect to the sale transactions in the particular assessment year. CO Nos. 6 to 21/GAU/2023 (in ITA Nos. 51 to 66/GAU/2023) 20. For the foregoing reasons, it is not possible to state that the impugned order

DCIT, CIRCLE-1, DIBRUGARH vs. BAJRANG LAL BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

reopen and/or assess the return with respect to six preceding years; however, there must be some incriminating material available with the Assessing Officer with respect to the sale transactions in the particular assessment year. CO Nos. 6 to 21/GAU/2023 (in ITA Nos. 51 to 66/GAU/2023) 20. For the foregoing reasons, it is not possible to state that the impugned order

D.C.I.T., CIRCLE- 1, DIBRUGARH vs. USHA BAMALWA, DIBRUGARH

In the result, all the appeals of the Revenue are dismissed and that of the Cross Objections of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

reopen and/or assess the return with respect to six preceding years; however, there must be some incriminating material available with the Assessing Officer with respect to the sale transactions in the particular assessment year. CO Nos. 6 to 21/GAU/2023 (in ITA Nos. 51 to 66/GAU/2023) 20. For the foregoing reasons, it is not possible to state that the impugned order