Rolex Rings Limited Vs DCIT/ACIT (ITAT Rajkot)
Summary: The appeal concerned reassessment proceedings for Assessment Year 2020-21 in the case of Rolex Rings Limited. The assessee had originally filed its return on 11/02/2021 declaring total income of Rs. 49,67,79,690/- and later revised it on 30/03/2021 declaring total income of Rs.49,47,46,930/-. Information from the Investigation Wing led the Assessing Officer to believe that the assessee was a beneficiary of an accommodation entry of Rs.5,40,00,000/- allegedly received from Rajesh Daftary and his concerns. A search under section 132 was conducted on the quoton group on 09-08-2022, following which the assessee’s case was reopened and notice under section 148 was issued on 28/03/2024.
The assessee challenged the reopening, the addition of Rs.5,40,00,000/- under section 69A read with section 115BBE, the treatment of amounts recorded in the books as unexplained income, denial of cross-examination and the validity of the reopening. Ground No.5 relating to the DIN issue was not pressed and was dismissed as not pressed. Before the Tribunal, the assessee contended that the reasons recorded did not identify tangible material, incorrectly stated that the assessee had taken a loan from Rajesh Daftary although the loan was from a bank, relied upon a third-party statement and documents which did not pertain to the assessee, and disclosed amounts already recorded in its books and return. The assessee also challenged the absence of a manual or digital signature on the approval under section 151 and the denial of cross-examination.
