“Assistant Director”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(9B) / Section 117731 judgments

The decision most relied on for Assistant Director is Vodithala Educational Society v. Assistant Director of Income (20 SOT 353), cited in 50 judgments on BharatTax.

Leading authorities on Assistant Director

Vodithala Educational Society v. Assistant Director of Income

20 SOT 353 · 2008 · ITAT

citing judgments

An educational institution that collects money over and above the prescribed rates, essentially acting as a vendor of education for profit, may not be considered a charitable institution under Section 2(15) and may be viewed as operating with a profit motive.

KLM Royal Dutch Airlines v. Assistant Director of Income Tax

304 ITR 264 · 2008 · High Court

citing judgments

Reassessment proceedings under Section 148 cannot be initiated if the original assessment proceedings, initiated based on a filed return, are still pending. This includes situations where the time for issuing a notice under Section 143(2) has not expired.

292 ITR 416(SC) Galileo Nederland BV v. Assistant Director of Income-tax, Circle-i(2), (Intl. Tax), New Delhi

367 ITR 319 · 2014 · High Court

citing judgments

The principle of consistency requires that the Assessing Officer or First Appellate Authority must follow decisions made in earlier years, unless there are good and sufficient reasons to deviate. An assessee's status should not be altered arbitrarily without assigning reasons or distinguishing facts.

STERLITE INDUSTRIES (INDIA) LTD. v. ASSISTANT COMMISSIONER OF INCOME-TAX AND ANOTHER

302 ITR 275 · 2008 · High Court

citing judgments

Information from the Enforcement Directorate indicating inflated purchases can serve as a valid basis for issuing a notice under Section 148 of the Income Tax Act, initiating reassessment proceedings.

Trib.) (v) Flying Fabrication v. Deputy Commissioner of Income-tax

133 Taxmann.com 84 · 2021 · High Court

citing judgments

The amendment to Section 36(1)(va) of the Income-tax Act made by the Finance Act, 2021, is prospective in nature, meaning payments made before the amendment are not affected by its retrospective application.

Jabalpur); Gopalkrishna Aswini Kumar v. Assistant Director of Income Tax

192 ITD 562 · 2022 · ITAT

citing judgments

Cases cited by this decision often involve assessment years 2018-19 and 2019-20.

Murasoli Trust v. Assistant Director of Income Tax (Exemptions IV), Chennai

65 Taxmann.com 186 · 2016 · Reported

citing judgments

A trust engaged in activities that constitute trade, commerce, or business is not entitled to claim its object as charitable if those activities fall foul of the proviso to section 2(15). Running a petrol outlet may not be considered a business incidental to the main object of a trust.

Ashapura Minichem Ltd. v. Assistant Director of Income-tax

40 SOT 220 · 2010 · ITAT

citing judgments

Income of a non-resident is deemed to accrue or arise in India if it falls under clauses (v), (vi), or (vii) of section 9(1), irrespective of whether the non-resident has a place of business or connection in India or has rendered services in India, due to the retrospective amendment of Section 9 by the Finance Act, 2010.

Judgments citing Assistant Director

M/S. S. Ramashandra Setty & Sons, Hassan vs. Income Tax Officer, Ward-1, Hassan

In the result, appeal of the assessee in ITA

ITA 1156/BANG/2023[2017-18]Status: DisposedITAT Bangalore10 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Shri C. Ramesh, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 115BSection 132(4)Section 250Section 69B

ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE

Ramzanali Asgar Khan, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-4(3)(1), Bengaluru

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 807/BANG/2024[2019-20]Status: DisposedITAT Bangalore07 Jun 2024AY 2019-20

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Sri Nayaz Pasha, A.RFor Respondent: Shri V. Parithivel, D.R

Section 143(1)Section 2(24)(x)Section 36(1)(a)Section 36(1)(va)Section 43B

declaring total income to the extent of Rs.1,43,44,710/-. The said return was processed under section 143(1) of the Act by Assistant Director Income Tax (learned AO.) Central Processing Department (CPC), Bengaluru vide an intimation dated 3.2.2020 by making additions under section

Ramzanali Asgar Khan, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-4(3)(1), Bengaluru

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 806/BANG/2024[2018-19]Status: DisposedITAT Bangalore07 Jun 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Sri Nayaz Pasha, A.RFor Respondent: Shri V. Parithivel, D.R

Section 143(1)Section 2(24)(x)Section 36(1)(a)Section 36(1)(va)Section 43B

ITO (It) TDS-2, Mumbai vs. Tata Steel Ltd, Mumbai

In the result, the appeal by the assessee is allowed, while the appeal by the Revenue is dismissed

ITA 225/MUM/2014[2007-08]Status: FixedITAT Mumbai07 Jun 2024AY 2007-08

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri J. D. Mistry a/wFor Respondent: Shri P. C. Chhotaray

Section 120(4)(b)Section 127Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)

Officer” has been defined in section 2(7A) of the Act as under:- “(7A) Assessing Officer" means the Assistant Commissioner or Deputy Commissioner or Assistant Director or Deputy Director or the Income-tax Officer who is vested with the relevant jurisdiction by virtue of directions or orders issued under

Tata Steel Ltd, Mumbai vs. Addl CIT 2(3), Mumbai

In the result, the appeal by the assessee is allowed, while the appeal by the Revenue is dismissed

ITA 8707/MUM/2011[2007-08]Status: DisposedITAT Mumbai07 Jun 2024AY 2007-08

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri J. D. Mistry a/wFor Respondent: Shri P. C. Chhotaray

Section 120(4)(b)Section 127Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)

S432 Kudimenahalli Primary Agricultural Co-Operative Credit Society, Deverahalli vs. Asst.Director of Income Tax, Bengaluru

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 195/CHNY/2024[2019-20]Status: DisposedITAT Chennai04 Jun 2024AY 2019-20

Bench: Shri Mahavir Singhand Shri Jagadish

For Appellant: Shri G. Baskar, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT

Section 143(1)Section 143(1)(a)Section 80P(2)(a)

return contains error/incorrect claims/inconsistencies which attracts adjustments and notice u/s.143(1)(a) of the Act dated 10.12.2020. The assessee filed the response. However, the Assistant Director of Income Tax, CPC rejected the response filed and disallowed the amount claimed as deduction u/s.80P(2)(a) of the Act. The ADIT

Om Kothari Foundation, Jaipur, Rajasthan vs. ITO, (Exemption) Ward-1, Jaipur, Rajasthan

In the result, the appeals of the assessee in ITA No

ITA 57/JPR/2024[2009-10]Status: DisposedITAT Jaipur04 Jun 2024AY 2009-10

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

For Appellant: Shri Anish Maheshwari, CAFor Respondent: Shri A.S. Nehra, Addl.CIT

Section 10Section 11Section 12ASection 13(1)Section 13(1)(d)Section 143(3)Section 147Section 164(2)

allowed by Hon’ble Court and Hon’ble ITAT. We rely following Cases on this issue 1. Escorts Cardiac Diseases Hospital Society v/s Assistant Director of Income- tax (Exemption), Trust Circle 2, New Delhi 18 Taxman.com (104) Delhi ITAT. Under section 11(1)(a) income derived from property held under

Louis Xavier D'Costa, Goa vs. Deputy Commissioner of Income-Tax, Circle-3(3)(1), Bangalore

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 749/BANG/2024[2017-18]Status: DisposedITAT Bangalore04 Jun 2024AY 2017-18

Bench: Shri George George K & Shri Waseem Ahmedr Assessment Year : 2017-18 Shri. Louis Xavier D’Costa, Vs. Dcit, H. No.86B C/O Inacio D’Costa, Circle – 3(3)(1), Belloi Nuvem, Bengaluru. Salcette – 403 601, Goa. Pan : Akgpd 2147 P Appellant Respondent Assessee By : Shri. Balaji, Ca Revenue By : Ms. Matta Padma, Addl. Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 03.06.2024 Date Of Pronouncement : 04.06.2024

For Appellant: Shri. Balaji, CAFor Respondent: Ms. Matta Padma, Addl. CIT(DR)(ITAT), Bengaluru

Section 139(1)Section 143(1)Section 250Section 91

various orders of the Tribunal which are detailed below:  Order of the Hon'ble ITAT in the case of Mr. Deepak Shimoga Padmaraju vs Assistant Director of income-tax, Bangalore in ITA No. 239/Bang/2024 (order dated 17.04.2024)  Order of the Hon'ble ITAT in the case of Mr. Shashidhar Seetharam ... Assistant Commissioner of Income Tax, Circle - 3 (1)(1), Bangalore in ITA No.29/Bang/2021 (order dated 07.03.2022)  Tanmoy Ghosh Vs. The Assistant Director of Income Tax, CPC, Bangalore in ITA Nos. 549/Bang/2022 (order dated 25.08.2022) Madua Bagchi Vs. The Assistant Director of Income Tax, Circle-61,  Kolkatta, in ITA No. 3/KOL/2017-18

Maya Kapoor, Gurgaon vs. Income Tax Officer, Ward-2(4), Gurgaon

The appeal of the assessee is allowed

ITA 783/DEL/2024[2021-22]Status: DisposedITAT Delhi31 May 2024AY 2021-22

Bench: Shri S Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Rakesh Gupta, Adv. and Shri Deepesh Garg, AdvFor Respondent: Shri Om Parkash, Sr. Dr

Section 139Section 143(1)Section 154Section 90

directory requirement and DTAA overrides the provisions of the Act and the Rules cannot be contrary to the Act. • Ganesh Anandrao Ingulkar vs. Assistant Director of Income-Tax in ITA NO. 302/MUM/2023 “10. Considered the rival submissions and material placed on record, we observe that assessee has filed Form

Suchi Agrawal, Noida vs. ITO Ward 5(2)(4), Noida

ITA 601/DEL/2024[2020-21]Status: DisposedITAT Delhi31 May 2024AY 2020-21

Bench: Shri S Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Akash Vajpai, Adv. and Ms. Shweta ShandiyalFor Respondent: Shri Om Prakash, Sr. Dr

Section 143(1)Section 154Section 90

ought to have considered while adjudicating the appeal, the decisions laid down by the Principal Bench, Delhi in Isha Mago Vs. Assistant Director of Income-tax, Central Processing Center (ITA No. 173/DEL/2024) Rameshwar Prasad Shrivastava Vs. ITO (ITA, No. 1839/Del/2023), Vikash Daga Vs. ACIT (ITA 2536/Del/2022), Ajay Kumar Mishra

Vpssr Facilities, Delhi vs. ITO, Ward-49(4), New Delhi

The appeal of the assessee is allowed for statistical purposes

ITA 3711/DEL/2023[2019-20]Status: DisposedITAT Delhi31 May 2024AY 2019-20

Bench: Cit(A) When Discussed The Same By Applying The Judgment Of Hon’Ble Supreme Court In Checkmate Services Pvt. Ltd. Vs. Cit-1, In Civil Appeal No.2833 Of 2016 & Ors.

Section 143Section 143(1)Section 2(24)Section 2(24)(x)Section 37(1)

taxmann.com 402 (Delhi - Trib.) (v) Premier Irrigation Adritec (P.) Ltd. Vs ACIT [2023] 146 taxmann.com 389 (Kolkata - Trib.) (vi) Ms.Nalina Dyave Gowda Vs Assistant Director of Income Tax [2023] 146 taxmann.com 420 (Bangalore - Trib.) (vii) Cemetile Industries Vs ITO [2022] 145 taxmann.com 209 (Pune - Trib.) (viii) Kwality Motel Shiraz

ITO, WD.9(1), Kolkata vs. M/S Maharaj Vincom Pvt. Ltd., Kolkata

ITA 35/KOL/2021[2009-10]Status: DisposedITAT Kolkata15 May 2024AY 2009-10

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.35/Kol/2021 Assessment Year: 2009-10 Ito, Ward-9(1), Kolkata……………….......................…...……………....Appellant Vs. M/S Maharaj Vincom Pvt. Ltd……............…..........................…..…..... Respondent 69, Jamunalal Bajaj Street, Kolkata- 700007. [Pan: Aafcm6496E] C.O. No.6/Kol/2023 (A/O I.T.A. No.35/Kol/2021) Assessment Year: 2009-10 M/S Maharaj Vincom Pvt. Ltd……............…..........................…....... Cross-Objector 69, Jamunalal Bajaj Street, Kolkata- 700007. [Pan: Aafcm6496E] Vs Ito, Ward-9(1), Kolkata …………..….......................…...……………....Respondent Appearances By: Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Assessee. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Department. Date Of Concluding The Hearing : March 07, 2024 Date Of Pronouncing The Order : May 15, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: This Appeal By The Revenue & Corresponding Cross-Objection By The Assessee Have Been Preferred Against The Order Dated 08.09.2020 Of The Commissioner Of Income Tax (Appeals)-7, Kolkata (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’).

Section 143(1)Section 143(3)Section 147Section 250Section 263

costs.” f) Same is also the mandate of Hon’ble Delhi High Court in [2007] 292 ITR 49 KLM Royal Dutch Airlines vs. Assistant Director of Income Tax wherein I.T.A. No.35/Kol/2021 & C.O. No.6/Kol/2023 Assessment Year: 2009-10 M/s Maharaj Vincom Pvt. Ltd. it has been held that where an assessment

Arathi Vinay Patil, Bangalore vs. Income Tax Officer, Ward-4(3)(4), Bengaluru

In the result, appeal of the assessee is allowed

ITA 604/BANG/2024[2019-20]Status: DisposedITAT Bangalore13 May 2024AY 2019-20

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2019-20

For Appellant: Smt. Suman Lunkar, A.RFor Respondent: Shri V. Parithivel, D.R

Section 115JSection 139(1)Section 143(1)Section 234ASection 44ASection 80Section 801ASection 80I

circumstances of the case, quashed the impugned Intimation as bad in law and void ab initio. 2. In any case without prejudice, the learned Assistant Director of Income Tax (CPC), Bangalore has erred in making an adjustment u/s. 143(1) which is not permitted by law. Such adjustment being

Rakesh Reddy Tanguturu, Hyderabad vs. ACIT., Circle-6(1), Hyderabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 229/HYD/2024[2019-20]Status: DisposedITAT Hyderabad09 May 2024AY 2019-20

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha, G. Hon’Ble Accounant Member Assessment Year: 2019-20 Rakesh Reddy Tanguturu, Vs. The Asst.Commissioner Of 8-2-293/82/F/A/65, Income Tax, Plot No.65-A, Circle – 6(1), Road No.14, Jubilee Hills, Hyderabad. Hyderabad, Telangana. Pan : Aaupy9817A. (Appellant) (Respondent) Assessee By: Shri Kumar Pal Tated, C.A. Revenue By: Shri Aves Madhukar, Sr.A.R. Date Of Hearing: 08.05.2024 Date Of Pronouncement: 09.05.2024 O R D E R Per Laliet Kumar, J.M. The Appeal Of The Assessee For A.Y. 2019-20 Arises From The Order Of Addl/Jcit (Appeals), Madurai, Dt.31.02.2024 Invoking Proceedings Under Section 143(1) Of The Income Tax Act, 1961 (In Short, “The Act”). 2. The Brief Facts Of The Case Are That Assessee, Who Is An Individual Having Income From Business, Other Sources & Agricultural Income. For The Year Under Appeal, In Addition To The Above Sources Of Income, The Assessee Had Also Reported Income From Capital Gains Being Gain On Redemption Of Mutual Funds. For The Previous Year Ending On 31.03.2019 Relevant To Ay 2019-20, The Original Return Of Income Was Filed Electronically On 27.09.2019 Admitting An Income Of Rs.1,35,05,760/- After Claiming Deduction Under Chapter Vi-A Of The Act. In The Original Return Of Income, The Assessee Had Also Reported Loss From Business Of Rs.40,21,673/-. The Business Loss Of Rs.40,21,673/- Was Not Set Off Against Any Other Source Of Income. Subsequently, The Return Was Revised On 21.08.2020 To Report The Revised Loss From Business To Rs.4,47,991/- From Rs.40,21,673/- . Even This Loss Of Rs.4,47,991/- Was Ignored In The Return, Meaning Thereby The Loss From Business Was Not Set Off Against Any Other Source Of Income Both In Original & Revised Return Of Income.

For Appellant: Shri Kumar Pal Tated, C.AFor Respondent: Shri AVES Madhukar, Sr.A.R

Section 143(1)Section 39Section 90

liability computed on the net adjusted total 2 income. The revised return was processed under section 143(1) of the Act by the Assistant Director of Income Tax, CPC, Bangalore vide intimation dated 22.01.2021. In the intimation, the relief of tax of Rs.13,86,933/- claimed under section

Markolines Infra Private Limited, Mumbai vs. ACIT/DCIT Circle 15(1)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2020-

ITA 366/MUM/2023[2019-20]Status: DisposedITAT Mumbai08 May 2024AY 2019-20

Bench: Shri Sandeep Singh Karhailshri Gagan Goyaland

For Appellant: Shri Pradip KapasiFor Respondent: Smt. Mahita Nair

Section 143Section 143(1)Section 143(1)(a)Section 250Section 36Section 36(1)(va)

assessee. The learned DR also furnished a certificate u/s 65B of the Evidence Act signed by the Assistant Director (Systems), Bangaluru to the effect that only authorised user knows the user address and password and can only make the changes. 12. We have considered the oral and written submissions

Markolines Infra Pvt Ltd., Belapur vs. ACIT/DCIT Circle-15(1)(1), Mumbai

ITA 1170/MUM/2023[2020-21]Status: DisposedITAT Mumbai08 May 2024AY 2020-21

Bench: Shri Sandeep Singh Karhailshri Gagan Goyaland

For Appellant: Shri Pradip KapasiFor Respondent: Smt. Mahita Nair

Section 143Section 143(1)Section 143(1)(a)Section 250Section 36Section 36(1)(va)

ACIT-15(1)(1), Mumbai vs. M/S Markolines Infra Pvt Ltd, Mumbai

ITA 2967/MUM/2022[2018-2019]Status: DisposedITAT Mumbai08 May 2024AY 2018-2019

Bench: Shri Sandeep Singh Karhailshri Gagan Goyal

For Appellant: Shri Pradip KapasiFor Respondent: Smt. Mahita Nair

Section 143Section 143(1)Section 143(1)(a)Section 250Section 36Section 36(1)(va)

Deputy Commissioner of Income Tax, Circle-8, Pune vs. Sandvik Coromant India Pvt Ltd, Pune

In the result, appeal filed by the Revenue in ITA

ITA 1072/PUN/2023[2018-19]Status: DisposedITAT Pune07 May 2024AY 2018-19

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.1072/Pun/2023 िनधा"रणवष" / Assessment Year : 2018-19 The Dy.Commissioner Of Sandvik Coromant India Pvt. Income Tax, Circle-8, Vs Ltd., Pune. Mumbai Pune Road, Dapodi, Pune – 411012. Pan: Aaccs6638K Appellant/ Revenue Respondent /Assessee Cross Objection No.7/Pun/2024 िनधा"रणवष" / Assessment Year : 2018-19 Sandvik Coromant India The Dy.Commissioner Of Pvt. Ltd., Vs Income Tax, Circle-8, Pune. Mumbai Pune Road, Dapodi, Pune – 411012. Pan: Aaccs6638K Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Patakh – Ar Revenue By Shri Ajay Kumar Keshari – Dr Date Of Hearing 15/04/2024 Date Of Pronouncement 07/05/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Ita 1072/Pn/2023 Filed By The Revenue & Cross Objection Co No.7/Pun/2024 Filed By The Assessee Are Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] U/S.250 Of The Act, For A.Y.2018-19

Section 139(1)Section 143(1)Section 143(1)(a)Section 250Section 251Section 251(1)(a)Section 43B

A.Y.2018-19. The said Return of Income was processed u/s.143(1) of the Income Tax Act, 1961 by Assistant Director of Income Tax, (Centralized Processing Centre), [ld.ADIT] Bangalore on 25.02.2020. In the order u/s.143(1), the ld.ADIT made a disallowance u/s.143(1)(a)(iv), the same is scanned and reproduced

Deepak Switch Gears Pvt. Ltd., Kolkata vs. PCIT, Asansol

In the result, the appeal of the assessee stands allowed

ITA 809/KOL/2023[2012-13]Status: DisposedITAT Kolkata07 May 2024AY 2012-13

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.809/Kol/2023 Assessment Year: 2012-13 Deepak Switch Gears Pvt. Ltd….…......................…...……………....Appellant 48/6, Suman Villa, 2Nd Floor, 155, Jessore Road, Kolkata-700055. [Pan: Aabcd1131H] Vs. Pcit, Asansol….....….........................................................…..…..... Respondent Appearances By: Shri A. K. Tibrewal, Ar, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : April 08, 2024 Date Of Pronouncing The Order : May 07, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Revision Order Dated 30.12.2022 Of The Principal Commissioner Of Income Tax, Kolkata [Hereinafter Referred To As ‘Pr. Cit’] Passed U/S 263 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In This Appeal Has Agitated Against The Action Of The Pr. Cit In Exercising His Revision Jurisdiction U/S 263 Of The Act & Thereby Directing The Assessing Officer To Frame The Assessment Afresh. 2. The Registry Has Pointed Out That The Appeal Is Time-Barred By 158 Days. A Separate Application Of Condonation Of Delay Has Been Filed, Wherein, It Has Been Pleaded That After Receipt Of The Impugned Order Of The Pr. Cit, The Assessee, Through Its Director, Shri Deep Kishan Saraf, Immediately Approached One Shri Pawan Kumar Agarwal, Chartered

Section 253Section 263Section 5

conducted, but because final findings was wrong and untenable. However, as per records available with this office, it is observed that the O/o the Assistant Director Of Income Tax (Inv.) (OSD), Unit-4, Kolkata carried out an investigation of transactions involving 02 firms namely Swiss Progressive Products

M/S R.S.Darshan Singh Motors Car Finance Pvt. Ltd., Kolkata vs. ITO, Ward-11(3), Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 265/KOL/2024[2013-14]Status: DisposedITAT Kolkata02 May 2024AY 2013-14

Bench: Sri Rajesh Kumar & Pradip Kumar Choubey

Section 143(1)Section 144BSection 147Section 148Section 250

depicts the reasons recorded for selection of the scrutiny u/s 147 of the Act and which as per the assessee is that the Assistant Director of Income Tax (Investigation) (OSD), Unit-4, Kolkata furnished an information in respect to STR Reference No. 1000054178 vide his letter No. ADIT(Inv)/Unit-4/Kol/S-55/STR