ITA No. 5983/Mum/2025 & CO No. 325/Mum/2025

Parties Involved

Facts Summary

The assessee, Anand Rathi Commodities Limited, is a company engaged in commodity broking. For Assessment Year 2018-19, the assessee filed its return of income declaring a loss. The case was selected for scrutiny, and the initial assessment accepted the returned loss without making any addition. Subsequently, proceedings for reopening the assessment were initiated, and the reassessment determined a total income by making certain disallowances. Aggrieved by the reassessment order, the assessee appealed to the Ld. CIT(A), which deleted the additions made by the Assessing Officer. The Revenue is now in appeal before the Tribunal, raising several grounds of appeal, while the assessee has filed a cross-objection challenging the validity of the reopening of the assessment.…

Legal Issues

• 1. Whether the Ld. CIT(A) erred in deleting the disallowance of ₹1,10,75,000 despite the assessee failing to substantiate that the said loss on operation/client claim was incurred wholly and exclusively for the purposes of business.
• 2. Whether the Ld. CIT(A) was justified in allowing the assessee’s claim of ₹1,10,75,000 as deductible under Section 37(1), without proper verification of the genuineness, necessity, and nexus of the expenditure with the business of the assessee.
• 3. Whether the Ld. CIT(A) was justified in deleting the disallowance of ₹3,08,35,862/- by holding that the said amount represents reversal of provision for doubtful debts earlier disallowed in the year of creation.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

Similar Judgements

• Prompt Commodities Limited Vs. ITO, Ward 12(1)

  Kolkata benchAY 2015-16Allowed

• Siddharth Fininvest Leasing Pvt. Ltd. vs. Income Tax Officer, Ward-4(1), Kolkata

  Kolkata Bench benchAY 2013-14Allowed

• Royal Fincomm Private Limited Vs. ITO, Ward 4(1), Kolkata

  Kolkata ‘D’ Bench benchAY 2015-16Partly Allowed

• Urveen Shivprasad Vyas Vs. The DCIT, Cir.2(1)(1) Ahmedabad

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• ITA No. 3415/Mum/2025 & CO No. 268/Mum/2025 (A.Y. 2014-15)

• M/s R.S. Vinimay Pvt. Ltd. Vs. ITO, Circle 11(3)

  D Bench, Kolkata benchAY 2016-17Allowed