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Income Tax Appellate Tribunal, “A” BENCH KOLKATA
Before: Shri Sanjay Garg & Dr. Manish Borad
order : December 14, 2023 आदेश / ORDER संजय गग�, �या�यक सद�य �वारा / Per Sanjay Garg, Judicial Member: The present appeal has been preferred by the assessee against the order dated 22.10.2021 of the National Faceless Appeal Centre (hereinafter referred to as the ‘CIT(A)’) passed u/s 250 of the Income Tax Act (hereinafter referred to as the ‘Act’).
In this appeal, the assessee, inter alia, has contested the validity of reopening of the assessment made by the Assessing Officer u/s 147 r.w.s 148 of the Act.
The assessee contested the reopening of the assessment on two grounds. Firstly that the Assessing Officer did not record valid reasons for forming belief regarding the escapement of the income of the Assessment year: 2012-13 Rahul Pandey assessee. Secondly that no approval of the competent authority was taken by the Assessing Officer u/s 151 of the Act.
Before proceeding further, we deem it fit to reproduce here the order of the Tribunal dated 08.05.2023 as under: