In the result, appeal of the assessee in ITA No

Bench: Shri Rajesh Kumar, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 67/Gty/2023 Assessment Year: 2014-15 M/S. Seema Holding Pvt. Ltd. I.T.O. Ward-15(2), Kolkata Vs [Now, Acit, Central Circle-1, 89, Muktaram Babu Street Guwahati] Kolkata - 700007 [Pan : Aadcs5209H] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent)

2) of the Act, we find that the AO has not made even a whisper to that effect, therefore, the essential condition precedent as stipulated in first proviso to section 147 of the Act has not been satisfied, therefore, the AO could not have usurped the jurisdiction without satisfying the same rendering the re- opening of assessment itself null