KTM Impex Private Limited vs. ITO, Ward 1
Case No: ITA No.2377/Del/2025
Court: INCOME TAX APPELLATE TRIBUNAL, DELHI BENCHES ‘A’: NEW DELHI
Date: 1/9/2026
Parties Involved
appellantKTM Impex Private Limited
respondentITO, Ward 1
Facts Summary
The case involves KTM Impex Private Limited, whose assessment for the year 2019-20 was reopened by the Assessing Officer (AO) based on information from a search operation conducted in the case of Galaxy Group. The AO issued a notice under section 148 of the Income-tax Act, 1961, alleging that KTM Impex had received accommodation entry amounting to Rs.50,00,000/- from M/s Highrise Securities & Trading Pvt. Ltd, controlled by Shri Himanshu Verma. The AO concluded that the genuineness of the unsecu…
Decision in favour of
Assessee
Legal Issues
- 1. Reopening of assessment u/s 147 is bad in law and void ab initio
- 2. Reassessment based on borrowed satisfaction and constitutes mere change of opinion
7 more legal issues analysed in this judgement.
Precedents Relied Upon
5 precedents cited in this judgement.