Bansiwala Iron & Steel Rolling Mill Vs DCIT (ITAT Jaipur)
The Income Tax Appellate Tribunal (ITAT), Jaipur Bench, allowed the appeal filed by the assessee against the order passed by the National Faceless Appeal Centre (NFAC)/Commissioner of Income Tax (Appeals) dated 28.07.2025 for Assessment Year 2010-11. The dispute related to additions made by the Assessing Officer (AO) on account of alleged clandestine removal of finished goods, unexplained sales, and unexplained investment based on findings of the Customs and Central Excise Department.
The assessee challenged the reopening of assessment under Sections 147 and 148 of the Income Tax Act, 1961, as well as additions made under Sections 69A and 69C. The grounds raised included objections to reassessment proceedings, alleged violation of the Supreme Court decision in GKN Driveshafts (India) Ltd. v. ITO, and challenge to additions based on estimated gross profit and unexplained capital.
The facts recorded by the Tribunal showed that a search and verification was conducted by the Department of Customs and Central Excise at the factory premises of the assessee. During the search, evidence allegedly indicating clandestine removal of finished goods was gathered. Based on this information, notice under Section 148 was issued on 19.03.2015 after obtaining approval from the specified authorities.
