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2025 Supreme(Online)(ITAT) 5564

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
S. Rifaura Rahman, Accountant Member, Anubhav Sharma, Judicial Member
M/s. NKG Infrastructure Limited – Appellant
Versus
DCIT, Central Circle 27 – Respondent


Advocates:
For the Appellants/Petitioners: Shri Rajat Jain, CA, Shri Akshat Jain, CA
For the Respondents: Shri Sunil Kumar Yadav, CIT DR

Table of Content
1. facts surrounding the assessment and return filing. (Para 1 , 2)
2. arguments regarding bogus purchases and their implications. (Para 3 , 4 , 5)
3. court observations on principles of natural justice. (Para 6 , 7 , 8)
4. ratio regarding reopening assessment and jurisdiction. (Para 9 , 10 , 11)
5. final conclusions and determination of the appeals. (Para 12 , 13)

ORDER

1. The Revenue and assessee has filed cross appeals against the order of ld. Commissioner of Income-tax (Appeals)-30, Delhi dated 12.08.2024 for Assessment Year 2013-14.

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2. Brief facts of the case are, assessee filed its original return of income for AY 2013-14 on 29.09.2013 declaring an income of Rs.19,64,12,030/-. The assessment in the case of the assessee was completed on 31.03.2016 under section 153A of the Income-tax Act, 1961 (for short ‘the Act’) read with section 143(3) determining the taxable income of Rs.22,21,63,617/-. The assessee is engaged in the business of civil construction and execution of infrastructure sector projects.

3. The information as received from Inside Portal of the Department and an investigation was conducted in the case of M/s. GP Trading Company by the Ghaziabad DDIT (Inv.)

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