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Ambika Tradelink (P) Ltd. vs. ITO, Wd-4(3), Kolkata

Case No: ITA No.761/KOL/2023
Court: Income Tax Appellate Tribunal 'A' Bench, Kolkata
Date: 3/25/2025

Parties Involved

appellantAmbika Tradelink (P) Ltd.
respondentITO, Wd-4(3), Kolkata

Facts Summary

The assessee, Ambika Tradelink (P) Ltd., filed a return of income declaring nil income and loss of ₹7,231 for the assessment year 2009-10. The case was reopened under section 147 of the Income-tax Act, 1961, based on information from the investigation wing indicating that the assessee was a beneficiary of accommodation entries amounting to ₹1,70,00,000. During a search and seizure operation at the business and residential premises of Mr. Santosh Kumar Shah, it was revealed that companies operated by him were involved in providing accommodation entries. The Assessing Officer issued statutory notices to the assessee, which were not complied with, leading to the addition of the unexplained cash credit to the assessee's income under section 144 of the Act.

Decision in favour of

Assessee

Legal Issues

  • 1. Invalid assumption of jurisdiction under section 147 of the Act without fulfilling precedent conditions by the Assessing Officer.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

2 precedents cited in this judgement.

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