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INCOME TAX APPELLATE TRIBUNAL (CHANDIGARH BENCH)
RAJPAL YADAV, VP, KRINWANT SAHAY, AM
The DCIT, Central Circle-2, Ludhiana – Appellant
Versus
Malbros International Pvt. Ltd. – Respondent
| Table of Content |
|---|
| 1. cross objections filed by the assessee. (Para 1 , 2 , 3) |
| 2. condonation of delay in filing cross objections. (Para 4 , 5) |
| 3. details of purchases and assessment history. (Para 6 , 9 , 10) |
| 4. revenue's grounds of appeal regarding bogus purchases. (Para 7 , 8) |
| 5. arguments based on legal precedents. (Para 11) |
| 6. court's analysis of evidence and legal standards. (Para 12) |
| 7. court's decision on reopening of assessment. (Para 13 , 14) |
| 8. final order dismissing appeals. (Para 15) |
ORDER
The present two appeals are directed at the instance of Revenue against the separate orders of ld. CIT (Appeals)dated 09.07.2024 passed for assessment year 2017-18 and2016-17.
3. The Registry has pointed out that both the Cross Objections are time barred by 26 days. The assessee has filed application for condonation of delay wherein it has been pleaded that earlier litigation was being held by Shri Varun Makhija, Tax Consultant, in whose opinion, no Cross Objection is to be filed because these are departmental appeals, however, when assessee contacted the Senior Counsel, then he opined to file Cross Objections challenging the re-opening of assessment. Accordingly, Cross Objections have been filed
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