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आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ

IN THE INCOME TAX APPELLATE TRIBUNAL

Hyderabad ‘A’ Bench, Hyderabad

(cid:302)ी रवीश सूद, माननीय Ûया(cid:467)यक सदèय एवं (cid:302)ी मधुसूदन साव(cid:875)डया, माननीय लेखा सदèय

SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER

AND

SHRI MADHUSUDAN SAWDIA HON’BLE ACCOUNTANT MEMBER

आयकरअपीलसं./I.T.A. No.1228/Hyd/2025

((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year:2022-23)

DCIT, VS. South Asian Ceramic Tiles

Circle-3(1), Private Limited,

Hyderabad. Hyderabad.

PAN: AAWCS4220R

(अपीलाथ(cid:568)/ Appellant) ((cid:292)×यथ(cid:568)/ Respondent)

: Shri Pawan Kumar Chakrapani, CA

करदाताका(cid:292)(cid:467)त(cid:467)न(cid:876)ध×व/

Assessee Represented by

: Ms. U. Mini Chandran, CIT-DR

राजèवका(cid:292)(cid:467)त(cid:467)न(cid:876)ध×व/

Department Represented by

: 21/01/2026

सुनवाईसमाÜतहोनेक(cid:551)(cid:467)त(cid:876)थ/

Date of Conclusion of Hearing

: 30/01/2026

घोषणा क(cid:551) तार(cid:547)ख/

Date of Pronouncement

ORDER

PER RAVISH SOOD, JM:

The present appeal filed by the revenue is directed against the

order passed by the Commissioner of Income Tax (Appeals), National

Faceless Appeal Centre, Delhi, dated 21/05/2025, which in turn arises

from the order passed by the Assessing Officer (for short, “AO”) under

section 143(3) r.w.s 144B of the Income Tax Act, 1961 (for short, “the

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ITA No. 1228/Hyd/2025

DCIT vs. South Asian Ceramic Tiles Pvt Ltd

Act”), dated 26/03/2024 for the Assessment Year (AY) 2013-14. The

revenue has assailed the impugned order of the CIT(A) on the following

grounds of appeal:

1. The Ld. CIT(A) erred both in law and on facts of the case in

allowing relief to the assessee.

2. That the Ld. CIT(A) erred in admitting additional evidence in

violation of Rule 46A of the Income Tax Rules, without affording the

Assessing Officer an opportunity to rebut or examine such evidence.

3. That the Ld. CIT(A) was not justified in rejecting the findings of the

Assessing Officer, which were based on clear discrepancies in the

assessee's financials and lack of satisfactory explanation for the

source of funds.

4. That the Ld. CIT(A) misinterpreted the scope of Section 69 and

wrongly held that the provisions were not applicable, despite the

assessee failing to substantiate the source of the investment with

credible evidence.

5. The Ld. CIT(A) erred in appreciating the requirements of invocation

of the provisions of section 69.

6. Appellant craves leave to amend or alter any ground or add any

other grounds. which may be necessary.”

2. Succinctly stated, the assessee company which is engaged in the

business of manufacturing of ceramic tiles had filed its return of income

for AY 2022-23 on 26/10/2022 declaring a loss of (Rs.18,74,49,155/-).

Thereafter, the case of the assessee company was selected for

complete scrutiny under the Faceless Assessment Scheme-2019 for

verification of certain issues, viz., (i) that the assessee company had

shown high liabilities in its balance sheet as compared to its low

income/receipts declared in the return of income; (ii) that the assessee

company had though disclosed significant amount of capital/loans

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ITA No. 1228/Hyd/2025

DCIT vs. South Asian Ceramic Tiles Pvt Ltd

during the year, but it had been consistently showing loss before

depreciation. Also, the introduction of funds in a business consistently

showing cash loss was unusual; and (iii) that there was a substantial

addition/introduction of tangible assets during the year which was

significantly more than the written down value (WDV) on the first day of

previous year as per the Income Tax Return filed by the assessee

company. Also, the value of the tangible assets shown by the assessee

company was required to be verified in the backdrop of the fact as to

whether or not the same were disclosed on the actual value or at a

higher value to claim higher depreciation.

3. Thereafter, the AO issued notices under section 143(2)/142(1) of

the Act.

4. During the course of the assessment proceedings, it was

observed by the AO that the assessee company had in its balance

sheet