Goldcity Properties Pvt. Ltd. Vs PCIT (ITAT Mumbai)
Summary: The appeal was filed by Goldcity Properties Pvt. Ltd. against the order dated 31 March 2019 passed by the Principal Commissioner of Income Tax-14, Mumbai under Section 263 of the Income-tax Act, 1961 for Assessment Year 2011-12. The assessee, a company engaged in consultancy, had originally filed its return on 20 September 2011 declaring total income of Rs. 40,033. The return was processed under Section 143(1).
The assessment was subsequently reopened under Section 147 on 23 March 2016 on the basis of information concerning alleged accommodation entries and, specifically, an amount of Rs. 7.25 crore received from Minaxi Suppliers Private Ltd. The Assessing Officer issued notice under Section 142(1) and specifically sought details concerning transactions with Minaxi Suppliers Private Ltd., including the nature of the transaction and bank statements. The assessee furnished explanations and supporting documents concerning the transaction, including its accounts, income-tax records, audited financial statements, company master data and details of directors. The assessee explained that the amount was received through banking channels as a contribution under a joint venture arrangement.
The reassessment was completed on 29 December 2016 under Section 143(3) read with Section 147 without making any addition and accepting the returned income.
