AMRIT CORPORATION,MUMBAI V. DCIT-CC-1(1), MUMBAI, MUMBAI

ITA 1662/MUM/2025

AI Insights

The case involves Amrit Corporation, the appellant, contesting an order from the National Faceless Appeal Centre (NFAC), Delhi, which pertained to the Assessment Year 2022-23. The dispute arose from an addition of Rs. 2,75,203 to the assessee's income, categorized as unexplained expenditure under section 69C of the Income-tax Act, 1961, following a search operation on Ratnakala Group, which revealed unaccounted transactions involving the assessee. The CIT(A) partly allowed the appeal for various years, but the assessee, further aggrieved, approached the Tribunal. However, due to non-appearance and non-submission of any written arguments by the assessee in multiple hearings, the Tribunal dismissed the appeal ex-parte.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 787580 (ITAT-MUMBAI)
• Duration Of Justice: 8 month(s) 7 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 17-11-2025
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: H
• Assessment Year: 2022-2023
• Appeal Filed On: 10-03-2025
• Laws Referred To: Income-tax Act, 1961
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: PRAVIN SALUNKHE
• Keywords: Reassessment proceedings; Unexplained expenditure; Retraction; Principle of natural justice
• Section: 69C

Judgement Text

"IN THE INCOME-TAX APPELLATE TRIBUNAL “H(SMC)” BENCH, MUMBAI BEFORE MS. KAVITHA RAJAGOPAL, JUDICIAL MEMBER & SMT.RENU JAUHRI, ACCOUNTANT MEMBER ITA No.1662/MUM/2025 7 (A.Y.2022-23) Amrit Corporation K-225/226, Ansa Industrial Estate, Saki Vihar Road, Sakinaka, Andheri (E), 400072. Vs. DCIT-CC-1(1), Pratishtha Bhawan, Mumbai-400020. \u0001थायी लेखा सं./जीआइआर सं./PAN/GIR No:AAFFA1022R Appellant .. Respondent Appellant by : None Respondent by : Shri Pravin Salunkhe, Sr. DR Date of Hearing 12.11.2025 Date of Pronouncement 17.11.2025 आदेश / O R D E R PER RENU JAUHRI [A.M.] :- This appeal is filed by the assessee against the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “CIT(A)”] dated 24.01.2025 passed u/s. 250 of the Income-tax Act, 1961 [hereinafter referred to as “Act”] for Assessment Year [A.Y.] 2022-23. 2. The grounds of appeal are as follows: “1. Under the facts and circumstances of the case and in law the L.d. CIT (A) has erred in conforming an addition of Rs.23,007/-being @ 8.36% of Rs.2,75,203/- of alleged purchase from M/s Ratnakala Exports Pvt. Ltd. Printed from counselvise.com P a g e | 2 ITA NO. 1662/mum/2025. 2. Under the facts and circumstances of the case and in law the Ld. CIT (A) has erred in ignoring the sworn affidavits of the Directors of Ratnakala Exports Pvt. Ltd. of retraction. 3. Under the facts and circumstances of the case and in law the Ld. CIT (A) has erred in ignoring the principles of natural justice for affording an opportunity to the appellant to cross examine the alleged evidences collated and relied upon in the reassessment proceedings. 4. The Appellant craves right to alter, amend, withdraw or substitute any ground or grounds or to add any new ground or grounds of appeal on or before the hearing.” 3. Brief facts of the case are that the assessee filed its return for A.Y. 2022- 23 declaring income of Rs. 40,87,150/- on 24.08.2022. The return was processed u/s. 143(1) of the Act. During a search action conducted in the case of Ratnakala Group, unaccounted transactions of the assessee with the group entities were found. Thereafter, a notice u/s. 143(2) was issued to the assessee on 21.02.2023 and assessment was completed at an income of Rs. 43,62,353/- after making an addition of Rs. 2,75,203/- u/s. 69C on account of unexplained expenditure. Aggrieved the assessee preferred an appeal before ld. CIT(A). Vide a common order in assessee’s appeals for various years including A.Y. 2018-19, the appeal of the assessee was partly allowed. Further aggrieved, the assessee has filed an appeal before the Tribunal. 4. On the date of last hearing on 12.11.2025 none was present on behalf of the assessee. It was noticed that there has been no compliance on the previous occasion when the case was fixed for hearing, except on the first date i.e on 09.09.2025 when a letter requesting for adjournment was filed Printed from counselvise.com P a g e | 3 ITA NO. 1662/mum/2025. by the assessee. Thereafter the case was fixed for hearing on 24.09.2025, 11.11.2025 and 12.11.2025. As neither anyone appeared on behalf of the assessee nor any written submissions have been filed, we, hereby, dismiss the appeal of the assessee ex-parte. 5. In the result, assessee’s appeal is dismissed. Order Pronounced in Open Court on 17.11.2025 Sd/- Sd/- (KAVITHA RAJAGOPAL) (RENU JAUHRI) (JUDICIAL MEMBER) (ACCOUNTANT MEMBER) Place: Mumbai Date 17.11.2025 Anandi.Nambi/STENO आदेश की \u0015ितिलिप अ\u001aेिषत/Copy of the Order forwarded to : 1. अपीलाथ\b / The Appellant 2. थ\b / The Respondent. 3. आयकर आयु\u0011 / CIT 4. िवभागीय ितिनिध, आयकर अपीलीय अिधकरण DR, ITAT, Mumbai 5. गाड\u001b फाईल / Guard file. स ािपत ित //True Copy// आदेशानुसार/ BY ORDER, उप/सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपीलीय अिधकरण/ ITAT, Bench, Mumbai. Printed from counselvise.com "