ABCI INFRASTRUCTURES PRIVATE LIMITED,KOLKATA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUWAHATI
In the result, the appeal of the assessee is allowed, whereas the appeal of the Revenue is dismissed
ITA 40/GTY/2022[2013-14]Status: HeardITAT Guwahati03 Apr 2023AY 2013-14
Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Borad
For Appellant: (1) That on the facts and in the circumstances of the case
Section 143(3)Section 147Section 148Section 153Section 153C
reassessment proceeding u/s. 147 by issue of a notice u/s.
148, in spite of the fact that none of conditions precedent existed and/or have been complied with and/or fulfilled by the Ld. A.O.
(2) That the Ld. CIT(A) was wholly wrong in not considering the fact that proceeding initiated u/s 147 of the IT Act, 1961
is completely