DCIT vs. Shrivallabh Pittie Industries Limited

Parties Involved

Facts Summary

The assessee, Shrivallabh Pittie Industries Limited, is a public limited company engaged in the manufacturing of yarn. It filed its return of income on 20.12.2017, declaring a total loss of Rs.126,34,91,000/-. A search and seizure action was carried out at the business premises of One World Industries Pvt. Ltd. and others on 06.11.2019. The Assessing Officer issued a notice under section 153C of the Income Tax Act, 1961 for assessment years 2014-15 to 2019-20 and under section 143(2) of the Act for assessment years 2020 to 2021. The assessee filed its return in response to the notice under section 153C of the Act. The Assessing Officer passed an assessment order on 15.03.2022, determining the total income at Rs.507,17,51,030/-, after making an addition on the balanced figure towards bogus purchases and sales amounting to Rs.45,69,89,091/- at 3% of the said amount, aggregating to Rs.1,37,09,672/-. The Revenue challenged the deletion of this addition by the Commissioner of Income Tax (Appeals).…

Legal Issues

• 1. Whether the Commissioner of Income Tax (Appeals) erred in deleting the addition of Rs.1,37,09,672/- under section 69C of the Income Tax Act, 1961 on account of alleged commission income?

Judgment Outcome

Decided in favour of Revenue.

Similar Judgements

• Prime Steel Industries Private Limited vs. The DCIT, Circle, Patiala

  Chandigarh bench

• M/s Nawla Ispat Pvt. Ltd. vs DCIT

  Delhi bench

• M/s Merino Industries Limited vs. DCIT, TDS Circle 1(1), Kolkata

  Kolkata Bench benchAY 2014-15, 2017-18, 2018-19, 2019-20, 2020-21, 2021-22, 2022-23, 2023-24, 2024-25, 2025-26Dismissed

• Manjeet Singh vs ITO

  Delhi Bench benchAY 2018-19Allowed

• Joint Commissioner of Income Tax, OSD vs. AFP Manufacturing Co. P. Ltd.

  Delhi Bench 'C' benchAY 2018-19Dismissed

• DCIT CC 1 4 Vs. Greyforce Industries Limited