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Income Tax Appellate Tribunal, ‘A’ BENCH, KOLKATA
Before: Sri J. Sudhakar Reddy & Sri S.S. Viswanethra Ravi
order : November 10, 2017 ORDER Per J. Sudhakar Reddy, Accountant Member :- This appeal by the assessee is directed against the order of the ld. Commissioner of Income Tax (Appeals)-Central-I, Kolkata [hereinafter the ‘ld. CIT(A)’], dated 17.09.2014 passed u/s 143(3)/147 of the Income Tax Act, 1961 (the ‘Act’) for the assessment year 2006-07 on the following grounds: “
1. That the learned CIT(A) erred in confirming that the reopening of assessment proceedings u/s 147 of the IT Act is valid and that there was no change of opinion of the AO.
2. That the learned CIT(A) erred in confirming the disallowance of the provision for loss on derivative transactions amounting to Rs.76,62,632/-.
3. That the appellant craves leave to add fresh ground and/or modify or substitute any grounds before or at the time of hearing.”
2. When the matter had come before the Bench on earlier occasions, the ld. Departmental Representative (DR) was directed to verify the assessment records and confirmed whether the allegations of the assessee that the reasons recorded for reopening of the assessment u/s 147 of the Act was not furnished to the assessee was correct or not.