Shiv Shakti Traders Vs ITO (ITAT Delhi)
The appeal and application for condonation of delay were filed by the assessee against the order dated 11.10.2024 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi under Section 250 of the Income-tax Act, 1961. The appeal arose from the assessment order dated 30.03.2022 passed by the Assessing Officer under Sections 147 read with 144B of the Act for Assessment Year 2017–18.
The assessee is a partnership firm engaged in wholesale and retail trading of iron and steel. The assessee filed its return of income on 31.03.2018 declaring a business loss of ₹68,98,172. The original assessment under Section 143(3) was completed on 16.12.2019 determining income at ₹56,60,67,770 after additions relating to unexplained bogus creditors, cash deposits, advances from customers, and disallowances under Sections 40(a)(ia), 40A(3), and 43B.
Subsequently, information was received from the Income Tax Officer, Ward-3(2), Saharanpur stating that cash had been deposited in the account of Mr. Manoj Kumar during the demonetisation period, out of which ₹15,00,000 had been transferred to the assessee. Based on this information, the case was reopened under Sections 147 and 148. A notice under Section 148 dated 28.03.2021 was issued. The assessee filed a return in response on 27.05.2021. Further notices under Section 143(2) dated 22.11.2021 and Section 142(1) were issued, and the assessee submitted replies dated 14.01.2022, 05.02.2022, and 15.03.2022.
