DCIT Vs Murlidhar Ratanlal Exports Limited (ITAT Kolkata)
ITAT Kolkata Quashes Reopening & Upholds CIT(A)’s Deletions
The Kolkata ITAT “C” Bench delivered a consolidated order on 28.10.2025 in the case of Murlidhar Ratanlal Exports Ltd. for A.Ys. 2013-14 to 2016-17 & 2018-19, dismissing all Revenue appeals & partly allowing the Assessee’s cross-objections.
Reopening beyond 4 years held invalid
AO reopened A.Y. 2013-14 on 01.04.2021, despite the original assessment u/s 143(3) being completed in 2016.
The Tribunal found no allegation of failure to disclose material facts, as required by the first proviso to s. 147, & relied on ACIT v. CEAT Ltd. [2023] 146 taxmann.com 108 (SC) to hold that the reopening was bad in law.
Hence, reassessments for A.Ys. 2013-14 & 2014-15 were quashed, rendering Revenue appeals infructuous.
Unsecured loans of ₹2.85 crore — addition deleted
For A.Y. 2015-16, the AO treated loans from seven companies as bogus u/s 68. CIT(A) found all loans through banks, repaid within or after the year, & creditors responded to notices. AO’s reliance on general “entry-operator” statements without cross-examination was rejected. ITAT upheld deletion, citing Ambe Tradecorp (P) Ltd. v. PCIT (145 taxmann.com 27 Guj.) & Calcutta HC rulings holding that repaid & verified loans can’t be taxed u/s 68.
