M/S Vinayak Financial Consultants Private Limited, Kolkata vs. D.C.I.T., Central Circle-4(1), Kolkata
In the result, appeal of the assessee is partly allowed for statistical
ITA 2695/KOL/2024[2013-14]Status: DisposedITAT Kolkata10 Jul 2025AY 2013-14
Bench: Shri George Mathan
For Appellant: Shri A.K.Tulsyan & Shri RobinFor Respondent: Smt. Madhumita Das, Sr.DR
Section 139(1)Section 143(1)Section 147Section 148
…icer is having proper reasons to believe and not merely on the fact that he has a reason to suspect that Income might have escaped assessment: 12.7 Decision dated 16.04.2018 by Hon'ble Bombay High Court In the case of CIT vs Mis Shodiman Investments Pvt Ltd [ 422 ITR 437], wherein the Hon'ble High Court Page | 10 13 ITA No.2695/KOL/2024 Pag explained the meaning of the phrase "reason to believe" (used in Sec 147 of the Act) and held the re-assessment proceedings initiated in that case as not sustainable in law. The relevant para of which are reproduced here, as under. "11....... it is clear that the reasonable…