Vedanta Resources Private Limited vs. Dy. Commissioner of Income Tax

Parties Involved

Facts Summary

The assessee, Vedanta Resources Private Limited, filed its return of income for the assessment year 2016-17 declaring an income of ₹6,100/-. A survey under section 133A of the Act was carried out on Saroj Group of cases, revealing that the assessee had merged with several entities and had bogus investments to the extent of ₹12,06,20,605/- as on 31.03.2016. Based on this information, the case of the assessee was reopened under section 147 of the Act by issuing a notice under section 148 of the Act on 17.03.2021. The assessee was issued notices under sections 143(2) and 142(1) of the Act, which were duly replied to. Finally, the Assessing Officer (AO) made an addition of ₹12,03,48,105/- as unexplained cash credit in the order framed under section 147 of the Act dated 31.03.2022.…

Legal Issues

• 1. Whether the re-opening of assessment by the AO was done mechanically and without application of mind.
• 2. Whether the assessment framed under section 147 of the Act dated 31.03.2022 was barred by limitation.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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