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M/s Majestic Sales Promotion Pvt. Ltd. vs. DCIT, Cir-8(1)

Case No: ITA Nos.47 & 48/KOL/2024
Court: Income Tax Appellate Tribunal 'B' Bench, Kolkata
Date: 3/28/2025

Parties Involved

appellantM/s Majestic Sales Promotion Pvt. Ltd.
respondentDCIT, Cir-8(1)

Facts Summary

The assessee, M/s Majestic Sales Promotion Pvt. Ltd., filed its return of income on 13.09.2011 declaring a total income of ₹12,83,718/-. The case was selected for scrutiny and assessed under section 143(3) on 24.03.2014. Subsequently, the case was reopened under section 147 of the Act on 22.03.2018 following a notice under section 148. The reopening was based on information received from the investigation wing indicating that the assessee had received accommodation entries amounting to ₹35.00 lacs from M/s Deergold Suppliers Pvt. Ltd. The Assessing Officer (AO) made an addition of ₹35.00 lacs on account of unexplained cash credit, treating it as bogus and non-genuine. The assessee contested this addition before the Commissioner of Income-tax (Appeals) but did not receive a specific adjudication on the issue.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the re-assessment proceedings initiated after 4 years from the end of the assessment year without there being a failure on the part of the assessee to disclose fully and truly any material facts is without jurisdiction being barred by limitation.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

1 precedent cited in this judgement.

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