Premier Vyapaar Pvt. Ltd., Kolkata vs. ITO, Ward - 15(2), Kolkata
In the result, both the appeals of assessee are allowed
ITA 1010/KOL/2018[2007-08]Status: DisposedITAT Kolkata02 Nov 2018AY 2007-08
Bench: Shri A. T. Varkey, Jm & Shri M. Balaganesh, Am] Assessment Year: 2007-08 Assessment Year: 2007-08 M/S. Premier Vyapaar Pvt. Ltd Vs. Income Tax Officer, Ward 15(2), Pan: Aadcp 8876D Kolkata Appellant/Assessee Respondent/Department
Section 143(2)Section 143(3)Section 144Section 147Section 148
…tion for reopening the assessment, it held. 45. The same view was expressed in Associated Stone Industries (Kotah) Ltd. v. CIT [1997] 224 ITR 5601 (SC). The Bombay High Court on the same issue in Hindustan Lever Ltd. v. R.B. Wadkar, Asstt. CIT (No. 1) [2004] 268 ITR 3322, held that the reasons in support of the proposed action under section 147 of the Act must necessarily reveal all facts or materials that had not been disclosed by the assessee fully and truly necessary for assessment so as to establish the link between the reasons and evidence. It was further held that the reasons so recorded cannot be suppleme…