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DCIT, CC-4(3), Kolkata vs. Avima Exports Pvt. Ltd.

Case No: ITA No.1708/Kol/2025
Court: Income Tax Appellate Tribunal, 'A' Bench, Kolkata
Date: 11/11/2025

Parties Involved

appellantDCIT, CC-4(3), Kolkata
respondentAvima Exports Pvt. Ltd.

Facts Summary

The assessee company, Avima Exports Pvt. Ltd., is a flagship concern of Avima Group, primarily engaged in trading jute products. The company filed its original return of income declaring a total income of Rs.33,10,000/-. The assessment was completed with a total income of Rs.47,53,370/-. Later, a survey operation revealed that the Avima Group had amassed unaccounted cash and brought it back into their books through bogus unsecured loans. The case was centralized, and reopening proceedings were initiated. The Assessing Officer determined the total income at Rs.6,10,14,650/- by making additions for unexplained cash credit, disallowance of interest expenses, and unexplained expenditure. The assessee appealed before the CIT(A), which allowed the appeal by deleting the additions. The revenue is now appealing before the Tribunal.

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the addition of Rs.5,24,50,000/- as bogus unsecured loan under Section 68 of the Act is valid.
  • 2. Whether the disallowance of Rs.35,49,027/- as interest expenses under Section 36(1)(iii) of the Act is valid.
  • 3. Whether the addition of Rs.2,62,250/- as commission paid to entry operators under Section 69C of the Act is valid.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

22 precedents cited in this judgement.

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DCIT, CC-4(3), Kolkata vs. Avima Exports Pvt. Ltd. | ITA No.1708/Kol/2025 | 2025 | Opakhya