DCIT Vs Goenka Rockwool India Private Limited (ITAT Raipur)
The appeal before the Income Tax Appellate Tribunal, Income Tax Appellate Tribunal, Raipur, arose from a common order of the CIT(Appeals)/NFAC dated 29.05.2025 for Assessment Year 2013–14. The assessee had originally filed a return declaring total income of ₹30.53 lakh, which was assessed under section 143(3) at ₹41.22 lakh. Subsequently, the case was reopened under section 147 based on information from the Commercial Tax Department, Raipur alleging that purchases were made from proprietorship concerns involved in bogus billing and not carrying out genuine business activities. In reassessment proceedings, the Assessing Officer made an addition of ₹1.77 crore on account of unexplained purchases, determining total income at ₹1.81 crore.
On appeal, the CIT(Appeals)/NFAC deleted the entire addition after admitting additional evidence under Rule 46A, including communications from the Commercial Tax Department, ledger accounts, bills, and proof of payments. The Revenue challenged this relief before the Tribunal, contending that the CIT(Appeals)/NFAC had violated Rule 46A(3) by admitting and relying upon additional evidence without obtaining or considering a remand report from the Assessing Officer. It was argued that although the Assessing Officer was asked to furnish a remand report, none was ultimately received, and relief was granted without compliance with the statutory procedure.
