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Income Tax Appellate Tribunal, “B” BENCH, KOLKATA
Before: SHRI RAJESH KUMAR, AM & SHRI SONJOY SARMA, JM
These are appeals preferred by the assessee against the orders of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 11.10.2023 & 12.10.2023 for the AYs 2010-11 & 2011-12 respectively.
ITA No. 48/KOL/2024 for A.Y. 2011-12
At the time of hearing, the assessee only pressed ground no.4, which is extracted as under:-
“4. For that the re-assessment proceedings initiated after 4 years from the end of assessment year without there being failure on the part of the assessee to disclose fully and truly any material facts is without jurisdiction being barred by limitation.” 03. The facts in brief are that the assessee filed the return of income on 13.09.2011, declaring total income at ₹12,83,718/-. The case of the
The said issue was raised before the ld. CIT (A) by way of raising ground no. 1 and 2 in an appeal , however, there was no specific adjudication on this issue by the ld. Commissioner of Income-tax (Appeals).
47/KOL/2024 for A.Y. 2010-12
The issue raised in this appeal is similar to one as decided by us in ITA No. 48/KOL/2024. Accordingly, our decision would apply mutatis
In the result, the appeals of the assessee are allowed.
Order pronounced in the open court on 28.03.2025.