Karrm Infrastructure Private Limited Vs CIT (ITAT Mumbai)
In the case of Karrm Infrastructure Private Limited vs. CIT (ITAT Mumbai), the appeal was filed by the assessee against an assessment order dated 12th February 2024 by NFAC, Delhi under section 147 for the Assessment Year 2013-14. Key points from the case are as follows:
Background: Karrm Infrastructure Private Limited, engaged in the business of construction of affordable houses, had initially declared a total income of Rs. 3,59,09,800/-. The assessment for the year was originally completed under section 143(3) on 20th March 2016, accepting the trading results and the declared purchases and sales.
Reopening of Assessment: The assessment was reopened under section 148 with a notice issued on 30th January 2021. This was based on allegations that certain payments amounting to Rs. 2,66,23,428/- made to various parties, including M/s. Shah Steel Corporation and M/s. Swarn Rerolling Mill Pvt. Ltd., were based on fake bills. It was discovered that these parties were non-filers of GST, leading the assessing officer to conclude that the purchases were unexplained.
Assessment Proceedings: The assessing officer (AO) rejected the assessee’s objections to the reopening without discussion and added the entire amount of Rs. 2,66,23,428/- to the income of the assessee.
