Mangalam Rice Mill Private Limited Vs ACIT (ITAT Kolkata)
The appeal concerned Mangalam Rice Mill Private Limited for AY 2015-16 against the NFAC/CIT(A) order dated 28.10.2025. The assessee had raised grounds challenging the reassessment and the addition arising from alleged bogus purchases, but the CIT(A) dealt with an earlier assessment order under section 143(3) dated 23.12.2019 and the cash-deposit issue, rather than the reassessment order under section 147 read with sections 144 and 144B dated 24.05.2023. The Tribunal therefore found that the appellate authority had not decided the actual grounds raised in Form No. 35 dated 05.07.2023 and remitted the issue to the CIT(A) for a fresh decision on those grounds.
The record before the Tribunal showed that the reassessment proceedings originated from information concerning alleged bogus purchases from M/s Shri Vaishno Devi Exim. The reassessment order made an addition of Rs.1,05,46,000/- under section 69C. The Tribunal noted that the CIT(A), however, had adjudicated the separate cash-deposit issue arising from the earlier section 143(3) order, including the addition of Rs.2,15,00,000/- relating to cash deposited in a PNB account during the demonetisation period. The Tribunal consequently directed the CIT(A) to pass an appropriate order in accordance with the assessee’s Form No.35 and directed the assessee to substantiate its case.
