Researchco Reprints Vs DCIT (ITAT Delhi)
Summary: The appeal was preferred by Researchco Reprints against the order dated 30.12.2024 passed by the Commissioner of Income Tax (Appeals), New Delhi under Section 250 of the Income-tax Act, 1961 for AY 2013-14. The CIT(A) had dismissed the assessee’s appeal. The original return was filed on 23.09.2013 declaring total income of Rs. 3,09,830/-. It was processed under Section 143(1) on 13.03.2015, and assessment under Section 143(3) was completed on 08.02.2016 at assessed income of Rs. 31,19,850/-.
A search, seizure and survey operation under Sections 132/133A was conducted on 17.12.2015 in the group of Mr. Anand Jain and Mr. Naresh Jain. During the operation, documents including ledgers and invoices were found and seized. The assessee was alleged to have taken accommodation entries for bogus purchases of Rs. 1,04,33,780/- from M/s Cream Sales Pvt. Ltd. and M/s Sunshine Inn Pvt. Ltd., described as paper/shell concerns of Shri Anand Kumar Jain and Shri Naresh Kumar Jain. The assessment was reopened under Section 147 by notice under Section 148 dated 14.03.2019 after prior approval/sanction under Section 151(1) from the Pr. CIT (Central)-03, New Delhi.
The Assessing Officer subsequently added Rs. 1,04,33,780/- as bogus purchases/accommodation entries and Rs. 2,08,675/- as commission allegedly paid in cash at 2% of the accommodation entries. The CIT(A) confirmed the additions. The assessee raised twelve concise grounds, principally challenging the jurisdiction for reopening, the validity of the sanction under Section 151, the alleged absence of failure to disclose material facts, the manual assessment order without DIN, the additions on account of bogus purchases and commission, and the enhancement of Rs. 64,00,706/- under Section 251.
