ITA No.669/Ahd/2025 & C.O. No.53/Ahd/2025

Parties Involved

Facts Summary

The assessee, Phoenix Flexibles Private Limited, filed its income return for the Assessment Year 2018-19 on 30.10.2018, declaring income of Rs.4,46,456/-. The Assessing Officer received information regarding accommodation entries and reopened the case, issuing a notice under Section 148 of the Income Tax Act, 1961 on 07.04.2022. The assessee filed replies during the assessment proceedings. However, the Assessing Officer was not convinced and passed an order under Section 147 r.w.s. 144 r.w.s. 144B of the Act on 11.03.2024, making additions of Rs.48,12,068/- under Section 68 and Rs.9,66,745/- under Section 69C of the Act. The assessee appealed to the First Appellate Authority, and the matter was decided by the Commissioner (Income Tax) for Appeals (CIT(A)), setting aside the order for fresh reassessment. Both the Revenue and the assessee are aggrieved by the CIT(A)'s order.…

Legal Issues

• 1. Whether the Ld. CIT(A) was correct in setting aside the matter to the file of the Assessing Officer for fresh assessment.
• 2. Whether the order of the Assessing Officer was passed ex-parte under Section 144 of the Act.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

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