Nezone Tubes Limited Vs DCIT (ITAT Kolkata)
The assessee filed two appeals before the Tribunal against separate orders of the Commissioner of Income Tax (Appeals) [CIT(A)] for Assessment Years (AY) 2011–12 and 2015–16. Both appeals were heard together and disposed of through a common order.
AY 2011–12 (ITA No. 179/KOL/2025)
The assessee, engaged in manufacturing M.S. pipes and galvanized pipes, originally filed its return and was assessed under Section 143(3) read with Section 153A. Subsequently, the assessment was reopened under Section 147 based on information from the Investigation Wing alleging that ₹42,61,133 received from a third party was an accommodation entry without actual sale of goods.
During reassessment, the assessee claimed that the amount represented genuine sales and furnished bank statements, ledger accounts, and invoices. However, it failed to provide supporting documents such as delivery challans, transport details, and proof of movement of goods. The Assessing Officer (AO) treated the amount as unexplained cash credit under Section 68, concluding that the assessee failed to prove the genuineness and creditworthiness of the transaction.
The CIT(A) upheld the reopening and addition, observing that the assessee did not provide sufficient documentary evidence to substantiate the transactions and that the investigation indicated layered fund transfers without actual movement of goods.
