TIGERHILL TRADELINK PRIVATE LIMITED,KOLKATA vs. ITO, WARD 10(2), , KOLKATA

We will first take up the appeal in ITA No.: 956/KOL/2025. Brief facts of the case are that the assessee company filed the return of income for A.Y. 2014-15 on 26/09/2014 declaring loss of Rs. 13,346/-. As per information received from DDIT (Inv.), the assessee had received fund amounting to Rs. 2,31,00,000/- from various shell entities allegedly through layering of transactions in its account. The assessment was completed u/s. 147 r.w.s 144B of the Act dated 29/05/2023 wherein Rs. 2,31,00,000/- was added u/s. 68 on account of unexplained cash credit. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who dismissed the appeal by giving his findings as under: “5.1 I have perused the facts of the case, grounds of appeal

1. raised, submissions made by the Appellant and other evidences on records. The Appellant has raised certain legal issues which I intend to dispose of first before proceeding to consider the Appeal on merits. 5.2 Ground 1, 2 and 5. The Appellant has submitted that the proceedings as initiated by the Assessing Officer under section 147 by issuing notice under section 148 of the Act are bad in law as there is no reason to believe that the income of the appellant has escaped assessment and further, the case has been reopened only on the basis of borrowed transaction. The Appellant has further submitted that the addition has been made by the AO on the basis of evidences collected behind the back of the Appellant and the same were never confronted. The Appellant has further submitted that he was not suitably heard in person although specific request was made in this regard. In this regard, I find that the same issue was raised by the Appellant in the course of assessment proceedings as well and has been discussed by the