IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, KOLKATA SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER (Assessment Year 2012-2013)

M/s Stupendors Traders Private Limited, 25, Strand Road, Room No. 613, Marshall House, Dalhousie, Kolkata - 700001 ……..…...…………….... Appellant [PAN: AADCS7524F]

vs.

DCIT, Circle-5(1), Kolkata, Ayakar Bhawan, P-7, Chowringhee Square, Kolkata - 700069 ……..…...…………….... Respondent Appearances by:

Assessee represented by : Siddharth Agarwal, Advocate Department represented by : P.N. Barnwal, CIT-DR Date of concluding the hearing : 21.08.2025 Date of pronouncing the order : 13.10.2025

O R D E R

PER SANJAY AWASTHI, ACCOUNTANT MEMBER

1. The present appeal arises from order dated 23.03.2023, passed u/s 250 of the Income Tax Act, 1961 (hereafter “the Act”) by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereafter “the Ld. CIT(A)]. The present matter involves second round proceedings as the first round was remanded back to the Ld. CIT(A) in the interests of natural justice (vide ITAT’s order dated 12.06.2019, ITA No. 2317/Kol/2017). The Ld. AO made an addition of Rs. 17,75,00,000/- u/s 68 of the