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 proceedings u/s. 147 pending proceedings u/s. 154?” We have heard Mr. Prithu Dudhoria, learned senior standing counsel for the appellant/department and Mr. Pratyush Jhunjhunwalla, learned counsel for the respondent/assessee. The assessee preferred appeal before the learned Tribunal against the order passed by the Commissioner of Income Tax (Appeals), Kolkata-21 [CIT(A)] dated 20.3.2023 by which

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 145(3) of the Act. The CIT(A) in its order dated 31.01.2019 first took up for consideration as regards the validity of the reopening of the assessment. On perusal of the 1 82 ITR 540 2 (1995) 214 ITR 801 (SC) 3 154 ITR 148 (SC) ITAT 175 OF 2021 Page 5 of 16 cash trail which

COMMISSIONER OF INCOME TAX (IT & TP) vs. M/S. DONGFANG ELECTRIC CORPORATION

Bench: : The Hon’Ble Justice Surya Prakash Kesarwani

3) SCC 207 (pragraphs 8, 10 & 11), the Hon’ble Supreme Court observed that issuance of notice to assessee under Section 274 is a consequence of prima facie satisfaction reached by the assessing officer in the assessment proceedings regarding concealment of particulars of income or furnishing of inaccurate particulars of income and held as follows: “8. The fact that notices