HPC Infotech Private Limited Vs ITO (ITAT Delhi)
In HPC Infotech Private Limited Vs ITO (ITAT Delhi), the appeal was filed against the order of the Commissioner of Income Tax (Appeals) dated 07.11.2025 for Assessment Year 2019–20. The assessee, engaged in import, distribution, and trading of UHF RFID tags and readers, had made foreign remittances amounting to Rs. 23,26,982/- during the relevant financial year to suppliers in China and the USA for procurement of inventory. These remittances were made through authorized banking channels and were not disputed in terms of business nature or purpose.
The Assessing Officer, however, made an addition of Rs. 23,13,542/- questioning the source of these remittances. The assessee explained that the funds were sourced through unsecured loans taken by its Directors from a lender, and furnished multiple supporting documents, including lender confirmations, income tax returns, bank statements, company financials, import documents, and remittance records. It was contended that both the Assessing Officer and the CIT(A) failed to examine these documents despite their availability on record.
The Tribunal observed that while the CIT(A) stated that documents were considered, there was no discussion or analysis of the nature of such documents or findings based on them. The core issue before the Tribunal was whether the assessee had substantiated the source of funds for the foreign remittances. It noted that the assessee had placed relevant documentary evidence on record to support the genuineness of the unsecured loans used for the remittances.
