Hotel Babylon Continental Private Limited Vs PCIT (Central) (ITAT Raipur)
The appeal before the ITAT Raipur challenged the order passed by the Principal Commissioner of Income Tax (Central), Bhopal under Section 263 of the Income-tax Act, 1961 dated 30.03.2024, which revised the reassessment order passed by the Assessing Officer under Sections 147 read with 143(3) dated 29.03.2022 for Assessment Year 2014-15. The Principal CIT had directed the Assessing Officer to frame the assessment afresh after verifying the creditworthiness of unsecured loans amounting to ₹1,88,56,508 and share capital and share premium aggregating ₹2,74,50,810 in the context of Section 68 of the Act.
The original assessment under Section 143(3) dated 29.08.2016 accepted the returned income. Subsequently, the Assessing Officer reopened the assessment under Section 147 on the basis of a belief that cash deposits of ₹36,59,500 (referred to elsewhere as ₹37,06,500) made by the assessee in its bank account during the relevant year had not been explained or reconciled with its books of account. During the reassessment proceedings, the Assessing Officer accepted the assessee’s explanation regarding the nature and source of the cash deposits and consequently made no addition on that issue while completing reassessment under Sections 147 read with 143(3) on 29.03.2022.
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