Gyan Enterprises Pvt. Ltd. (AY: 2012-13)
Case No: ITA No.2401/Del/2025
Court: INCOME TAX APPELLATE TRIBUNAL, 'A' BENCH, DELHI
Date: 1/9/2026
Parties Involved
appellantGyan Enterprises Pvt. Ltd.
respondentACIT, Circle 10(2)
Facts Summary
The assessee, Gyan Enterprises Pvt. Ltd., a non-banking financial company, filed its return declaring a business income of Rs. 8,04,59,896/- for the assessment year 2012-13. Subsequently, the case was reopened under sections 147/148 of the Income Tax Act, 1961, based on information received that the assessee had paid Rs. 70,00,000 in cash for the purchase of a 16 carat yellow diamond ring from Nirav Modi/Firestar Group during FY 2011-12. The Assessing Officer (AO) relied on statements and digita…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the reopening of the assessment for AY 2012-13 under section 147 is bad in law.
- 2. Whether the AO erred in making additions under section 69B on account of the jewellery purchase alleging that Rs. 70 lakhs was paid in cash.
Precedents Relied Upon
4 precedents cited in this judgement.