PRINCIPAL COMMISSIONER OF INCOME TAX 5 KOLKATA vs. DEBABRATA BANERJEE
Accordingly, the appeal fails and the same is dismissed
ITAT/292/2024HC Calcutta18 Jul 2025
Bench: : The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- Hon'Ble Justice Chaitali Chatterjee (Das) Date : 18Th July, 2025.
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 144Section 147Section 260ASection 69A
69A
read with section 115BBE of the Act?
2. Whether on the facts and in the circumstances of the case, the Learned
Income Tax Appellate Tribunal was justified in law in holding that the
2
reopening of assessment has been made in violation of the 1st proviso to
Section 147 of the Act without considering the fact that the assessee