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2025 Supreme(Online)(ITAT) 6963

INCOME TAX APPELLATE TRIBUNAL (KOLKATA BENCH)
SHRI RAJESH KUMAR, AM, SHRIPRADIP KUMAR CHOUBEY, JM
DCIT, Central Circle 4(3) – Appellant
Versus
AVIMA Exports Private Limited – Respondent


Advocates:
For the Appellants: Shri Manish Tiwari, AR
For the Respondents: Shri Raja Sengupta, DR

ORDER

Per Rajesh Kumar, AM:

This is an appeal preferred by the Revenue against the order of the Commissioner of Income-tax (Appeals), Kolkata-27(hereinafter referred to as the “Ld. CIT(A)”] dated 22.03.2025 for the AY 2014-15.

02. The appeal of the Revenue is time barred by 2 days. Considering the facts and circumstances of the case, we find that there is plausible reason to condone the delay and the delay of filing the appeal is hereby condoned.

03. The issue in Ground No. 1 by the Revenue is against the deletion of addition of Rs. 8,48,75,000/- by the Ld. CIT(A) as made by the AO on account of unexplained cash credit in respect of unsecured loans u/s 68 of the Act.

04. The facts in brief are that the assessee is engaged in the business of trading in jute products. During the year the return of income was filed on 26.09.2014 declaring total income of Rs. 51,08,970/-. The case of the assessee was selected under scrutiny and assessment was accordingly framed u/s 143(3) of the Act vide order dated 13.12.2016 assessing the income at Rs. 53,13,420/- A survey was conducted on 04.11.2019 u/s 133A of the Act during which certain documents were seized. During the course of survey, the survey te

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