Frozen Iron and Steel Private Limited Vs DCIT (ITAT Delhi)
₹1 Crore s.68 Addition Remanded—Assessee Denies Receipt from Alleged Entry Provider; Given One Final Opportunity
Assessee challenged addition of ₹1,00,00,000 u/s 68, made on the basis of Investigation Wing Kolkata report alleging that Cyprus Multitrade Pvt Ltd (a shell company managed by Praveen Aggarwal group) routed accommodation entries to Assessee. AO issued notices u/s 142(1), 133(6) & SCN dated 06.12.2019, but Assessee did not respond during assessment. AO therefore treated the ₹1 crore as unexplained cash credit. CIT(A) (24.03.2025) confirmed addition, noting that Assessee merely denied receiving funds but produced no evidence to rebut the detailed fund-flow trail established by the Investigation Wing.
Before ITAT, Assessee reiterated that no money was ever received from Cyprus Multitrade, and sought opportunity to file all documents. Tribunal examined CIT(A)’s findings , including the recorded chain of shell companies—Sharda Vanijya → Parmeshwar Merchandise → Link Point Construction → Sampark Advisory → Suryamukhi Projects → Khushboo Complex → Cyprus Multitrade—ultimately leading to alleged credit to the Assessee.
Since Assessee’s stand is a complete denial of receipt, but no documentary proof was filed earlier, Tribunal held that one final opportunity must be given in the interest of justice. Matter restored to AO for de novo adjudication, with liberty to Assessee to file all evidence to prove non-receipt or identity/genuineness issues.
