M/S REPOSTI FINCO PRIVAE LIMITED ,KOLKATA vs. I.T.O.,WARD-10(4), KOLKATA

order : October 26, 2021 Hearing through Video Conferencing ORDER Per Bench: The present appeal has been preferred by the assessee against the revision order dated 21.02.2019 of the Principal Commissioner of Income Tax (Appeals)-4, Kolkata (hereinafter referred to as ‘PCIT’) passed u/s 263 of the Income Tax Act (hereinafter referred to as the ‘Act’). At the outset, the ld. counsel for the assessee has submitted that no show-cause 2. notice/notice of hearing was ever received by the assessee from the ld. PCIT. He, in this respect, has invited our attention to Para 3 of the impugned order, wherein, the ld. PCIT has mentioned that the notice u/s 263 of the Act was served upon the assessee through affixation. It has not been pointed out that why the notice was issued through affixation. However, from the above observation, it is apparent that the show-cause notice u/s 263 of the Act was not served upon the assessee in normal course. Under these circumstances, the ld. counsel for the assessee has submitted that the assessee may be given opportunity to reply to the show-cause notice of the ld. PCIT and to present his case before the ld.