Supra Financial Services Limited Vs ITO (ITAT Delhi)
The appeals were filed against the order dated 31.07.2025 passed by the Commissioner of Income Tax (Appeals)-30, New Delhi for Assessment Year 2016–17. The first appeal arose from an assessment order passed under Sections 143(3)/147 of the Income Tax Act, 1961, and the second appeal arose from an order passed under Section 154. Since both appeals involved common issues, they were heard together and disposed of through a common order.
The case arose from information received by the Assessing Officer (AO) from the Investigation Wing after a search conducted on 13.04.2017 under Section 132(4) on the Himanshu Verma Group. During the search proceedings, it was found that Himanshu Verma allegedly provided bogus accommodation entries through shell companies and dummy directors. Based on this information, the AO noted that during the relevant year the assessee had entered into transactions amounting to Rs. 3.30 crore with Syala Buildwell Pvt. Ltd. (SBPL) and Rs. 40 lakh with Stabilitas Estate Pvt. Ltd. (SEPL).
The assessee had originally filed its return on 16.10.2016, declaring a total income of Rs. 27,73,600, which was processed under Section 143(1). Subsequently, based on the investigation report, the AO formed the opinion that income had escaped assessment and initiated reassessment proceedings under Section 147, issuing a notice under Section 148. The assessee filed objections to the reopening, but the AO rejected them on the ground that they were not submitted within the prescribed period of 60 days from the receipt of recorded reasons.
