PRINCIPAL COMMISSIONER OF INCOME TAX 9 KOLKATA vs. P L GOENKA HUF

Accordingly, the appeal filed by the revenue is allowed and the substantial

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

reassessment contemplated under Section 147 of the Act would include “borrowed information” and the same ought not to be mistaken

AI CHAMPDANY INDUSTRIES LTD. vs. COMMISSIONER, INCOME TAX, CENTRAL - II KOLKATA , WEST BENGAL

In the result, we find that the order of the

Bench: : The Hon’Ble Justice T.S. Sivagnanam

reassessment on 30.3.2001 under Section 143(3) read with Section 147 of the Act disallowing the deduction under Section 80HHC

PRINCIPAL COMMISSIONER OF INCOME TAX-1, KOLKATA vs. ARSHIA GLOBAL TRADECOM PRIVATE LIMITED

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

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 147 authorises and permits the assessing officer to assess or reassess income chargeable to tax, if he has reason

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. PHILIPS INDIA LTD

Accordingly, the appeal fails and is dismissed

Bench: : The Hon’Ble Chief Justice T.S Sivagnanam

reassessment under section 147 of the Act was put to challenge. The learned Tribunal carefully examined the factual position more

PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL 2 KOLKATA vs. PEARL TRACOM PVT LTD

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

reassessment order was passed under section 143(3) read with section 147 of the Act reckoning the income to be Rs.79

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. ANCHITA PROPERTIES PVT LTD

Accordingly, the both appeals fail and are dismissed

Bench: : The Hon’Ble The Chief Justice T.S. Sivagnanam & The Hon’Ble Justice Chaitali Chatterjee (Das) Dated : 3Rd July, 2025 Appearance: Mr. Tilak Mitra, Adv. Mr. Amit Sharma, Adv...For Appellant

Section 147 of the Income Tax Act, 1961 2 by ignoring the findings of the Assessing Officer and the surrounding circumstances of the case? ii) Whether on the facts and in the circumstances of the case the Learned Tribunal was justified in law to quash the reassessment

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. M/S PURPLE SUPPLIERS PVT LTD

The appeals are dismissed and the substantial

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

147 of the Act passed by the Assistant Commissioner of Income Tax, Circle-5(1), Kolkata, dated 30.1.2018. 4 6. The first aspect which has been considered by the Tribunal as well as by us is with regard to the validity of the reopening of the assessment for all the three years. It is seen that

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. M/S PURPLE SUPPLIERS PVT LTD

The appeals are dismissed and the substantial

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)

147 of the Act passed by the Assistant Commissioner of Income Tax, Circle-5(1), Kolkata, dated 30.1.2018. 4 6. The first aspect which has been considered by the Tribunal as well as by us is with regard to the validity of the reopening of the assessment for all the three years. It is seen that

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. SUBHALAXMI CHEM PVT LTD

Accordingly, the appeal fails and is dismissed

Bench: : The Hon’Ble Chief Justice T.S Sivagnanam

reassessment order passed under Section 143(3) read with 147 of the Act dated 26.11.2018 as upheld by the appellate

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. MANISH JAIN

Bench: : The Hon’Ble Chief Justice T.S Sivagnanam

reassessment proceedings under Section 147 of the Income Tax Act, 1961 on the premise that the notices under Section 2 148 and Section

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. MANISH JAIN

Bench: : The Hon’Ble Chief Justice T.S Sivagnanam

reassessment proceedings under Section 147 of the Income Tax Act, 1961 on the premise that the notices under Section 2 148 and Section

COMMISSIONER OF INCOME TAX, KOLKATA-II, KOLKATA vs. M/S. USHA MARTIN VENTURES LTD.

Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

Section 147 of the Act. On facts, the learned Tribunal found that the issue of loss/expenditure incurred in respect of newly undertaken software product development project as capital loss/expenditure was not touched by the assessing officer in the reassessment

PRINCIPAL COMMISSIONER OF INCOME TAX 1 KOLKATA vs. FATEH CHAND CHINDALIA

The appeal is dismissed and the questions of law are

Bench: : The Hon’Ble The Chief Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 22Nd January, 2024 Appearance : Mr. Vipul Kundalia, Sr. Adv. Mr. Soumen Bhattacharjee, Adv. Ms. Oindrila Ghosal, Adv. …For Appellant Mr. S.M. Surana, Sr. Adv. …For Respondent

Section 147 dated 28.12.2018 concluded that the source of investment is made out of accumulated Bank balance of the assessee, whereas as per records the said accumulated Bank balance has come from sale of penny share M/s. Tuni Textiles Ltd. After elaborate hearing of the learned Advocates for the parties and carefully perusing the materials placed on record, we find

M/S R R SONS TRADING COMPANY vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-XVI, KOLKA

The appeals are dismissed

Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 10Th May, 2022. Appearance:- Ms. Chandrani Das, Adv. Ms. Riti Basu, Adv.

reassessment proceeding was a clear case of change of opinion when the materials contained in the recorded reasons where already available with the department much before and also at the time of making the original assessment under section 143(3)? III) Whether, on the facts and in the circumstances of the case, the order of the Tribunal was clearly erroneous

M/S LEOPARD FINANCIERS PVT LTD. vs. ASSISTANT COMMISSIONER OF INCOME TAX

The appeals are dismissed

Bench: : The Hon’Ble Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 10Th May, 2022. Appearance:- Ms. Chandrani Das, Adv. Ms. Riti Basu, Adv.

reassessment proceeding was a clear case of change of opinion when the materials contained in the recorded reasons where already available with the department much before and also at the time of making the original assessment under section 143(3)? III) Whether, on the facts and in the circumstances of the case, the order of the Tribunal was clearly erroneous

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. RAHUL PREMIER INDIA AGENCY PRIVATE LIMITED

Accordingly, the appeal fails and the same is dismissed

Bench: : The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- Hon'Ble Justice Chaitali Chatterjee (Das) Date : 5Th August, 2025. Appearance : Mr. Aryak Datt, Adv. Mr. Prithu Dudhoria, Adv. …For Appellant.

reassessment order without considering the fact that the reopening was made on the basis of specific and credible information from the investigation wing of the department ? 2. Whether in facts and in the circumstances of the case the Ld.Income Tax Appellate Tribunal was not justified in law in deleting the addition of 2 Rs.40,00,000/- on account of unexplained

PRINCIPAL COMMISSIONER OF INCOME TAX 2 KOLKATA vs. M/S DANIEL COMMODITIES PRIVATE LIMITED

The appeal is dismissed

Bench: : The Hon'Ble Justice Rajarshi Bharadwaj & The Hon’Ble Justice Uday Kumar Date : 14Th January, 2026

reassessment order passed by the Assessing Officer u/s 147 of the Act was without jurisdiction and, therefore, the same was non-est. He has submitted that the subsequent revision order passed by the ld. PCIT u/s 263 of the Act and the consequent order passed by the Assessing Officer u/s 143(3) r.w.s sec. 263 of the Act were, therefore

PRINCIPAL COMMISSIONER OF INCOME TAX 1 KOLKATA vs. M/S THE PEERLESS GENERAL FINANCE AND INVESTMENT CO LTD.

Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA

147 of the said Act as without issuing a notice under Section 143(2) since the assessee did not file any return in response to Notice under Section 148 of the Act despite well settled proposition of law that mere non-issuance of a Notice under Section 143(2) of the Act will not vitiate and/or make the reassessment