Murari Lal Harish Chand Jaiswal Pvt. Ltd. vs DCIT

Parties Involved

Facts Summary

The assessee company, Murari Lal Harish Chand Jaiswal Pvt. Ltd., is engaged in the business of manufacturing tobacco products. The company filed its return of income for Assessment Year 2018-19 on 28.09.2018, declaring an income of INR 1,09,82,630/-. The case was selected for scrutiny under CASS for issues related to ICDS compliance and adjustment and income under section 56(2)(x). Statutory notices under sections 143(2) and 142(1) were issued, and an addition of INR 2,32,89,787/- was made under section 56(2)(x). A search and seizure action was carried out by the Department on 06.01.2021, and proceedings under section 153A were initiated. The assessment under section 153A was completed on 22.12.2021 with a total income of INR 3,42,72,420/-. The assessee filed an appeal against this order, which was dismissed by the Ld. CIT(A) on 19.12.2024, confirming the addition under section 56(2)(x).…

Legal Issues

• 1. Sustainability of the addition made by the assessing officer based on an infructuous assessment order under section 143(3).
• 2. Erroneous adoption of earlier assessed income by the assessing officer under section 153A/143(3).
• 3. Upholding of the addition under section 56(2)(x) by the CIT(A).
• 4. Restricting the disallowance under section 56(2)(x) to INR 1,81,53,778/-.
• 5. Contravention of the provisions of section 153D of the Income Tax Act, 1961 by the assessment order.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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