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INCOME TAX APPELLATE TRIBUNAL (PUNE BENCH)
Manish Borad, Accountant Member, Vinay Bhamore, Judicial Member
Pankaj Infrastructures Pvt. Ltd. – Appellant
Versus
DCIT, Circle-4, Pune – Respondent
| Table of Content |
|---|
| 1. factual background of original assessment and reopening. (Para 3 , 4 , 5 , 6) |
| 2. reassessment valid due to non-disclosure of material facts. (Para 7 , 8 , 9 , 10 , 11 , 12 , 13 , 14 , 15) |
| 3. advance payment not allowable as bad debt under section 36. (Para 16 , 17 , 18) |
| 4. transaction sham; disallowance upheld per khyati realtors. (Para 19 , 20 , 21) |
| 5. assessee's appeal dismissed. (Para 22) |
आदेश/ORDER
PER VINAY BHAMORE, JM:
This appeal filed by the assessee is directed against the order dated 27.08.2025 passed by Ld. CIT(A)/NFAC for the assessment year 2012-13.
2. The appellant has raised the following grounds of appeal :-
“1) On the facts and in the circumstance of the case and in law the ld. CIT(A) erred in confirming the action of the AO in initiating the reassessment proceedings u/s.147 purely on the basis of original assessment record and without any new tangible material available with the AO after completion of original assessment proceedings and accordingly the reassessment order is liable to be quashed.
2) On the facts and in the circumstance of the case and in law the ld. CIT(A) erred in confirming the action of the AO in initiating the reassessment proceedings
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