IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI BEFORE SHRI MAHAVIR SINGH, HON’BLE VICE PRESIDENT &

SMT. RENU JAUHRI, HON’BLE ACCOUNTANT MEMBER ITA No. 6419/DEL/2025; Assessment Year: 2014-15 Mahaveera Rice World (known Vs DCIT as Mahavira Rice World LLP) Circle 46(1)

5581, Lahori Gate Delhi- 110006 Delhi (APPELLANT) (RESPONDENT)

PAN No. AAUFM7235K Assessee Represented by : Shri S.K Gupta, CA Revenue/Department Represented by : Shri Ajay Kumar Arora, Sr. DR Date of Hearing: 28.01.2026 Date of Pronouncement: 13.02.2026 ORDER PER RENU JAUHRI :

The above captioned appeal is preferred by the assessee against the order dated 24.07.2025, passed by Ld. CIT(A)/NFAC, Delhi u/s 250 of the Income Tax Act, 1961 [hereinafter referred to as, “Act”] for A.Y. 2014-15. Assessment was framed by AO u/s 147 r.w.s 144 r.w.s 144B of the Act., vide order dated

25.05.2023.

2. The assessee has raised following grounds of appeal: “(i) On the facts and circumstances of the case, the authorities below has erred both on facts and in law in upholding the initiation of the reassessment proceedings and consequent impugned order as the same has been initiated by issue of notice u/s 148 and completed u/s 147/144/144B in the name of the non-existing entity ignoring the fact that the information regarding takeover of the erstwhile assessee firm by a private limited company and dissolution of the erstwhile assessee firm was in the knowledge of the department.

(ii) The reassessment proceedings and consequent reassessment both are invalid and without jurisdiction as the said assessment has been initiated and completed without complying with legal requirements of the provisions of section 147, 148, 148A, 151, 149 of the Income Tax Act therefore such assessment is void ab initio and liable to be quashed.

(iii) The Ld. CIT(A) has erred both in law and on facts in the case in upholding the disallowance of Rs.58,19,782/- u/s 69C treating the same as bogus purchase in terms of provisions of sec 69C of the Act ignoring the fact that the above provision has no applicability as the purchases are duly accounted in books of account and above addition has been made without rejecting books of accounts u/s 145(3) of IT Act.

(iv) The CIT(A) has erred both in law and in facts of the case in upholding the aggregate addition of Rs.58,19,782/- allegedly treating the purchases made from M/s Gayatri Maa Enterprises and M/s Parth International as bogus purchases having held the same as unexplained expenditure within meaning of sec 69C of IT Act ignoring the submission of appellant with evidences filed. The above addition is made ignoring the fact that there is no expenditure of this amount which is out of books of account of appellant. In view of above, the above addition is not tenable in law.

(v) The appellant craves leave to add, DLEETE, modify amend the above grounds of appeal with the permission of the Hon’ble appellate authority.”

3. Although the assessee has raised several grounds, we first take up the legal ground no. (i) wherein the issue of notice has been challenged on the ground that it has been issued on a non-existing entity.

4. Brief facts are that the return for A.Y 2014-15 by the assessee firm M/s Mahaveera Rice World, was filed on 07.08.2014, declaring total income of Rs. 15,64,030/-. Original assessment was completed u/s 143(3) by ITO Ward 46(2) Delhi vide order dated 21.12.2016 at assessed income of Rs. 21,54,330/-.

Subsequently, as the business of the firm was taken over by a private limited company viz., M/s Mahavira Rice World Pvt. Ltd., the firm was dissolved vide dissolution deed dated 31.03.2018. The information regarding closure of business and surrender of PAN was filed before the Ld. AO as well as ITO TDS Ward 75(3).

4.1 A survey action u/s 133A was conducted on 31.11.2018 in the case of Sh. Ashok Kumar Gupta and others who were found to be engaged in providing accommodation entries for non-genuine purchases and sales to various parties. It was noted tha