Vardhaman Gem Exports Pvt. Ltd. vs. The ITO, Ward 5(3)(1)

Parties Involved

Facts Summary

The Assessing Officer completed the reassessments for the assessment years 2013-14 and 2014-15 by separate orders dated 21.03.2023. An addition of Rs.20,76,17,499/- was made in 2013-14 and Rs.8,89,55,823/- in 2014-15 under section 68 read with section 115BBE of the Act. The first appellate orders passed by the learned CIT(A) were set aside by the Tribunal vide order dated 13.06.2025. The matters were restored to the learned CIT(A) for fresh adjudication. In the second round, the learned CIT(A), by the impugned orders dated 26.02.2026, again confirmed the action of the Assessing Officer. The assessee is, therefore, in further appeal before the Tribunal.…

Legal Issues

• 1. Whether the fresh notices issued under section 148 on 29.07.2022 were within the period of limitation.
• 2. Whether the reassessment proceedings and the assessment orders dated 21.03.2023 were without jurisdiction.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

Similar Judgements

• Jayshree Ravi Sancheti vs. Dy. Commissioner of Income Tax, Circle - 27(1), Mumbai

  Mumbai bench

• Golekh Bihari Jena vs. Income Tax Officer, National Faceless Assessment Center, Delhi

  Cuttack bench

• Dynamic Transmission Ltd. vs. ACIT, CIRCLE, ROHTAK

  Delhi Bench benchAY 2013-14, 2014-15Allowed

• ITA No. 3354/Del/2016 : Asstt. Year : 2004-05

  Delhi Bench ‘E’, New Delhi benchAY 2004-05Allowed

• Sh. Praveen Gupta Vs. ACIT, New Delhi

  Delhi Benches 'F', New Delhi benchAY 2008-09Dismissed

• Mansi A. Sheth vs ITO-29(2)(3), Mumbai

  Mumbai bench