Zeliant Corp vs. Income Tax Officer, Ward 36(1), Delhi

Parties Involved

Facts Summary

The appellant is a partnership firm coming into existence w.e.f. 31.07.2025 through a deed of partnership executed on that date between two partners Sh. Apurv Jain and Sh. Shlshu Sharma. The assessee made cash deposits of Rs. 67,25,000/- during demonetization and Rs. 5,57,000/- in the remaining period of F.Y. 2016-17. The assessing officer issued notices u/s 142(1) and 144(1)(b) of the Act but the assessee failed to provide a valid explanation for the deposits. The AO added Rs. 72,82,000/- as unexplained money u/s 69A r.w.s 115BBE. The CIT(A) restored the matter to the AO for deciding the case afresh after verifying all the new evidence.…

Legal Issues

• 1. Non-service of assessment order as per prescribed procedure.
• 2. Addition of Rs. 83,50,900/- u/s 69A rws 115BBE.
• 3. Incorrect assessment order passed in the status of AOP instead of as a partnership firm.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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