ITA No.674/AHD/2026

Parties Involved

Facts Summary

The Appellant filed his original return of income for the Assessment Year 2020-2021 under Section 139(1) of the Income Tax Act, 1961, declaring total income of INR 3,51,360/- on a gross turnover of INR 17,56,800/- (net profit declared at 20%). Subsequent to search and survey action on M/s Ambica Ashish Tradelink LLP, information was received from DDIT Unit-2(1), Ahmedabad regarding cash collections and unaccounted transactions. Based on this information, the Assessing Officer initiated reassessment proceedings under Section 147 of the Act by issuing notice under Section 148 on 31/03/2024, alleging that purchase transactions of INR 1,80,000/- from Ambica Ashish Tradelink LLP had resulted in escapement of income. The Assessing Officer passed Assessment Order, dated 27/03/2025, under Section 147 read with Section 144/143(3) of the Act making an addition of INR 1,80,000/- as unexplained expenditure under Section 69C read with Section 115BBE of the Act. The appeal preferred by the Assessee was dismissed ex-parte by the Ld. CIT(A) vide Order, dated 23/09/2025, on grounds of non-compliance, confirming the addition made by the Assessing Officer. Being aggrieved, the Assessee has preferred the present appeal before the Tribunal.…

Legal Issues

• 1. Ground Nos. 2 and 4
• 2. Ground Nos. 1, 3, 5, 6 and 7 to 7.3

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

Similar Judgements

• Mohanlal Premraj Shah vs. Income Tax Officer-Ward-5

  Surat bench

• Krishna Associates vs ITO, WARD-3(3)(1), Ahmedabad

  Ahmedabad bench

• Tigerhill Tradelink Private Limited Vs. ITO, Ward-10(2), Kolkata

  Kolkata ‘D’ Bench, Kolkata benchAY 2014-15Partly Allowed

• Nissim Traders Pvt. Ltd. vs Asst. CIT, Circle 10(3)(1)

  Mumbai bench

• Frontier Raas Exports Private Limited and GNE Exports Private Limited v. Central Circle 26

  Delhi bench

• Ashok Kumar Jain vs DCIT

  Delhi "A" Bench: New Delhi benchAY 2016-17Allowed