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

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2012-13 Ratna Infrastructure Projects Vs. The Income Tax Officer, Ward –3(3), Private Limited, Hyderabad. Hyderabad. Pan : Aadcr5836P. (Assessee) (Respondent) Assessee By: Shri Mohd. Afzal, Advocate. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 20.01.2025 Date Of Pronouncement: 12.02.2025

40A(3) of the IT Act. Therefore, erred in confirming additions made by Assessing Officer in reassessment proceedings amounting to Rs.273,02,94,670/-. 5. The learned Commissioner ought to have appreciated that notice u/s 148 is issued on account of a letter from ADIT Kolkata, in respect of a transaction amounting to Rs.5,64,94,670/- and further