RITIN LAKHMANI,KOLKATA vs. PR.CIT - 10 , KOLKATA

In the result, all the appeals filed by the assessees are allowed

Bench: Sri J. Sudhakar Reddy & Ms. Madhumita Roy)

revised u/s 263 of the Act by the Pr. CIT. These two paragraphs do not state that the ld. Pr. CIT had on examination of the records initiated proceedings u/s 263 of the Act. The Pr. CIT has, after perusing the proposal of the AO, which was before him along with the record, came to a prima facie conclusion

REETA LAKHMANI,KOLKATA vs. PR.CIT - 10 , KOLKATA

In the result, all the appeals filed by the assessees are allowed

Bench: Sri J. Sudhakar Reddy & Ms. Madhumita Roy)

revised u/s 263 of the Act by the Pr. CIT. These two paragraphs do not state that the ld. Pr. CIT had on examination of the records initiated proceedings u/s 263 of the Act. The Pr. CIT has, after perusing the proposal of the AO, which was before him along with the record, came to a prima facie conclusion

RACHIT LAKHMANI ,KOLKATA vs. PR.CIT - 10, KOLKATA

In the result, all the appeals filed by the assessees are allowed

Bench: Sri J. Sudhakar Reddy & Ms. Madhumita Roy)

revised u/s 263 of the Act by the Pr. CIT. These two paragraphs do not state that the ld. Pr. CIT had on examination of the records initiated proceedings u/s 263 of the Act. The Pr. CIT has, after perusing the proposal of the AO, which was before him along with the record, came to a prima facie conclusion

RAVISH LAKHMANI ,KOLKATA vs. PR.CIT - 10 , KOLKATA

In the result, all the appeals filed by the assessees are allowed

Bench: Sri J. Sudhakar Reddy & Ms. Madhumita Roy)

revised u/s 263 of the Act by the Pr. CIT. These two paragraphs do not state that the ld. Pr. CIT had on examination of the records initiated proceedings u/s 263 of the Act. The Pr. CIT has, after perusing the proposal of the AO, which was before him along with the record, came to a prima facie conclusion

PRAVESH KUMAR LAKHMANI ,KOLKATA vs. PR.CIT - 10 , KOLKATA

In the result, all the appeals filed by the assessees are allowed

Bench: Sri J. Sudhakar Reddy & Ms. Madhumita Roy)

revised u/s 263 of the Act by the Pr. CIT. These two paragraphs do not state that the ld. Pr. CIT had on examination of the records initiated proceedings u/s 263 of the Act. The Pr. CIT has, after perusing the proposal of the AO, which was before him along with the record, came to a prima facie conclusion

GOPICHAND LAKHMANI ,KOLKATA vs. PR.CIT - 10, KOLKATA

In the result, all the appeals filed by the assessees are allowed

Bench: Sri J. Sudhakar Reddy & Ms. Madhumita Roy)

revised u/s 263 of the Act by the Pr. CIT. These two paragraphs do not state that the ld. Pr. CIT had on examination of the records initiated proceedings u/s 263 of the Act. The Pr. CIT has, after perusing the proposal of the AO, which was before him along with the record, came to a prima facie conclusion

JAIKISHAN LAKHMANI ,KOLKATA vs. PR.CIT - 10 , KOLKATA

In the result, all the appeals filed by the assessees are allowed

Bench: Sri J. Sudhakar Reddy & Ms. Madhumita Roy)

revised u/s 263 of the Act by the Pr. CIT. These two paragraphs do not state that the ld. Pr. CIT had on examination of the records initiated proceedings u/s 263 of the Act. The Pr. CIT has, after perusing the proposal of the AO, which was before him along with the record, came to a prima facie conclusion

NANDILAL RUNGTA,KOLKATA vs. DCIT, CC-V, KOLKATA, KOLKATA

In the result, the appeals of the assessee in ITA Nos

Bench: Shri M. Balaganesh, Am & Shri S. S. Viswanethra Ravi, Jm]

condone the delay in filing of appeals by the assessee in ITA No. 1317/Kol/2016 and ITA No. 1319/Kol/2016 and admit those appeals for adjudication. 6 ITA Nos.1317-1320/Kol/2016 Mukund Rungta & Nandlal Rungta.., AY 2010-11 3. The primary facts which triggered the revision proceedings u/s 263

MUKUND RUNGTA,KOLKATA vs. DCIT, CC-V, KOLKATA, KOLKATA

In the result, the appeals of the assessee in ITA Nos

Bench: Shri M. Balaganesh, Am & Shri S. S. Viswanethra Ravi, Jm]

condone the delay in filing of appeals by the assessee in ITA No. 1317/Kol/2016 and ITA No. 1319/Kol/2016 and admit those appeals for adjudication. 6 ITA Nos.1317-1320/Kol/2016 Mukund Rungta & Nandlal Rungta.., AY 2010-11 3. The primary facts which triggered the revision proceedings u/s 263

M/S. GARG BROTHERS PVT. LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE - 3(2), KOLKATA , KOLKATA

In the result, appeal of the assessee is allowed

Bench: Shri A. T Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं/.Ita No.2519/Kol/2017 ("नधा"रणवष" / Assessment Year: 2009-10) M/S. Garg Brothers Pvt. Ltd. Vs. Dcit, Central Circle- 3(2), Kolkata 57, Burtolla Street, Aayakar Bhawan Poorva, 110, Kolkata – 700 007. Shantipally, Kolkata – 700 107. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No. : Aaacg 9775 F (Assessee) .. (Revenue) & आयकरअपीलसं/.Ita No.2520/Kol/2017 ("नधा"रणवष" / Assessment Year: 2009-10) M/S. Cliff Treximpvt. Ltd. Vs. Dcit, Central Circle- 3(2), Kolkata 57, Burtolla Street, Aayakar Bhawan Poorva, 110, Kolkata – 700 007. Shantipally, Kolkata – 700 107. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No. : Aabcc 0961 E (Assessee) .. (Revenue) & आयकरअपीलसं/.Ita No.2521/Kol/2017 ("नधा"रणवष" / Assessment Year: 2009-10) M/S. Span Foundation Pvt. Vs. Dcit, Central Circle- Ltd. 3(2), Kolkata Aayakar Bhawan Poorva, 110, 57, Burtolla Street, Shantipally, Kolkata – 700 107. Kolkata – 700 007. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No. : Aaecs 4605 C (Assessee) .. (Revenue)

condone the delay and admit the appeal for hearing. 4. These three appeals filed by the different assessee’s emanate from a common search conducted at their premises, involves common and identical issues, therefore, appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, since facts remain similar and the grounds

M/S. CLIFF TREXIM PVT. LTD., ,KOLKATA vs. DCIT, CENTRAL CIRCLE - 3(2), KOLKATA , KOLKATA

In the result, appeal of the assessee is allowed

Bench: Shri A. T Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं/.Ita No.2519/Kol/2017 ("नधा"रणवष" / Assessment Year: 2009-10) M/S. Garg Brothers Pvt. Ltd. Vs. Dcit, Central Circle- 3(2), Kolkata 57, Burtolla Street, Aayakar Bhawan Poorva, 110, Kolkata – 700 007. Shantipally, Kolkata – 700 107. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No. : Aaacg 9775 F (Assessee) .. (Revenue) & आयकरअपीलसं/.Ita No.2520/Kol/2017 ("नधा"रणवष" / Assessment Year: 2009-10) M/S. Cliff Treximpvt. Ltd. Vs. Dcit, Central Circle- 3(2), Kolkata 57, Burtolla Street, Aayakar Bhawan Poorva, 110, Kolkata – 700 007. Shantipally, Kolkata – 700 107. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No. : Aabcc 0961 E (Assessee) .. (Revenue) & आयकरअपीलसं/.Ita No.2521/Kol/2017 ("नधा"रणवष" / Assessment Year: 2009-10) M/S. Span Foundation Pvt. Vs. Dcit, Central Circle- Ltd. 3(2), Kolkata Aayakar Bhawan Poorva, 110, 57, Burtolla Street, Shantipally, Kolkata – 700 107. Kolkata – 700 007. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No. : Aaecs 4605 C (Assessee) .. (Revenue)

condone the delay and admit the appeal for hearing. 4. These three appeals filed by the different assessee’s emanate from a common search conducted at their premises, involves common and identical issues, therefore, appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, since facts remain similar and the grounds

M/S. SPAN FOUNDATION PVT. LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE - 3(2), KOLKATA , KOLKATA

In the result, appeal of the assessee is allowed

Bench: Shri A. T Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं/.Ita No.2519/Kol/2017 ("नधा"रणवष" / Assessment Year: 2009-10) M/S. Garg Brothers Pvt. Ltd. Vs. Dcit, Central Circle- 3(2), Kolkata 57, Burtolla Street, Aayakar Bhawan Poorva, 110, Kolkata – 700 007. Shantipally, Kolkata – 700 107. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No. : Aaacg 9775 F (Assessee) .. (Revenue) & आयकरअपीलसं/.Ita No.2520/Kol/2017 ("नधा"रणवष" / Assessment Year: 2009-10) M/S. Cliff Treximpvt. Ltd. Vs. Dcit, Central Circle- 3(2), Kolkata 57, Burtolla Street, Aayakar Bhawan Poorva, 110, Kolkata – 700 007. Shantipally, Kolkata – 700 107. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No. : Aabcc 0961 E (Assessee) .. (Revenue) & आयकरअपीलसं/.Ita No.2521/Kol/2017 ("नधा"रणवष" / Assessment Year: 2009-10) M/S. Span Foundation Pvt. Vs. Dcit, Central Circle- Ltd. 3(2), Kolkata Aayakar Bhawan Poorva, 110, 57, Burtolla Street, Shantipally, Kolkata – 700 107. Kolkata – 700 007. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No. : Aaecs 4605 C (Assessee) .. (Revenue)

condone the delay and admit the appeal for hearing. 4. These three appeals filed by the different assessee’s emanate from a common search conducted at their premises, involves common and identical issues, therefore, appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, since facts remain similar and the grounds

HILL QUEEN INVESTMENT PVT. LTD,KOLKATA vs. PCIT-2, KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Sri J. Sudhakar Reddy, Hon’Ble & Sri Aby T. Varkey, Hon’Ble) Assessment Year: 2015-16 Hill Queen Investment (P) Ltd...……………………....................................……………..…….............Appellant Surobala Apartments Flat No. 202 3Rd Floor Block-B Rekhjuani, Bhatinda Rajarhat Kolkata – 700 135 [Pan : Aaacj 2324 P] Vs. Pr. Commissioner Of Income Tax -2, Kolkata..................…………...............................…......Respondent Appearances By: Shri S.M. Surana, Advocate, Appeared On Behalf Of The Assessee. Shri Devi Sharan Singh, Cit, D/R, Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : April 6Th, 2021 Date Of Pronouncing The Order : April 21St, 2021 Order Per J. Sudhakar Reddy, Am :- This Appeal Filed By The Assessee Is Directed Against The Order Of The Learned Principal Commissioner Of Income Tax (Appeals) - 2, (Hereinafter The “Ld. Cit(A)”), Passed U/S. 263 Of The Income Tax Act, 1961 (The ‘Act’), Dt. 20/03/2020, For The Assessment Year 2015-16. 2. There Is A Delay Of 223 (Two Hundred Twenty Three) Days In Filing Of This Appeal By The Assessee. After Perusing The Petition For Condonation For Delay, We Are Convinced That The Assessee Was Prevented By Sufficient Cause In Filing The Appeal In Time. Hence, We Condone The Delay & Admit The Appeal. 3. The Assessee Is A Company & Filed Its Return Of Income For The Assessment Year 2015-16, Disclosing Total Income Of Rs.20,40,470/- On 28/09/2015. The Case Was Selected For Limited Scrutiny For The Following Reasons:- “(I) Mismatch In Sales Turnover Reported In Audit Report & Itr (Ii) Mismatch In Amount Paid To Related Persons U/S 40A(2)(B) Reported In Audit Report & Itr (Iii) Suspicious Sale Transaction In Shares (Penny Stock Tab In Its)”

263 of the Income Tax Act, 1961 (the ‘Act’), dt. 20/03/2020, for the Assessment Year 2015-16. 2. There is a delay of 223 (two hundred twenty three) days in filing of this appeal by the assessee. After perusing the petition for condonation for delay, we are convinced that the assessee was prevented by sufficient cause in filing the appeal

M/S ROSEMARY VINCOM LLP ,KOLKATA vs. ITO, WARD 47(5), KOLKATA

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

Bench: Sri J. Sudhakar Reddy & Sri Aby T. Varkey)

Delay of 186 days in filing of the appeal is condoned as the reason given is COVID-19 Pandemic. 2. The assessee is a company and is in the business of trading and filed its return of income for the AY 2015-16 on 11.01.2016 declaring total income of ₹2,21,638/-. The assessment was selected for limited scrutiny under

CONCORD INFRA PROJECTS PVT. LTD., KOLKATA vs. PCIT-3, KOLKATA

In the result, the appeal of assessee is allowed

Bench: Hon’Ble Shri A. T. Varkey, Jm & Shri Manish Borad, Am]

condone the delay and admit the appeal for hearing. 3. The ground of appeal of the assessee reads as under: 1. For that the assumption of jurisdiction u/s 263 of the Act by the Ld. Pr. CIT is wrong and uncalled for. 2. For that the Ld. Pro CIT having not examined the records of the appellant and proceeded

M/S. PEARL TRACOM PVT. LTD.,KOLKATA vs. PCIT-4, KOLKATA, KOLKATA

Bench: Sri Rajpal Yadav & Dr. Manish Borad

condone the delay and admit the appeal for adjudication on merits. 3. The assessee is in appeal before this Tribunal raising the following grounds: “1. For that in view of the facts and in the circumstances, the Ld. PCIT was wholly unjustified in setting aside the order passed by the AO u/s 263/143(3) dt. 30.12.2016 holding the said order

SHRINGAR MARKETING PVT. LTD,KOLKATA vs. PCIT-4, KOLKATA

In the result, appeal of the assessee is allowed

condone the delay and admit this appeal of the assessee. 2. The assessee is a company and had filed its return of income for the Assessment Year 2015-16 on 21/09/2015, disclosing total income of Rs.9,54,200/-. The company had issued shares at a premium during the year. The case was selected for scrutiny through CASS and issued notices

JYOTI RANJAN ROY REPRESENTED BY LIMITED GUARDIAN SUVAJIT ROY ,KOLKATA vs. ACIT, CIR. 50, KOLKATA

In the result, all the captioned appeals of the assessee are allowed for statistical purposes

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.963/Kol/2024 Assessment Year: 2006-07 Jyoti Ranjan Roy Represented By Limited Guardian Suvajit Roy.............................……….……Appellant Block Ac-155, Sector-1, Salt Lake City, Kolkata-700064. [Pan:Adlpr2179P] Vs. Acit, Circle-50, Kolkata.............…..….…..….........……........……...…..…..Respondent I.T.A. No.314/Kol/2017 Assessment Year: 2006-07 Jyoti Ranjan Roy ……………………………..............................……….……Appellant Block Ac-155, Sector-1, Salt Lake City, Kolkata-700064. [Pan: Adlpr2179P] Vs. Acit, Circle-50, Kolkata.............…..….…..….........……........……...…..…..Respondent I.T.A. No.261/Kol/2024 Assessment Year: 2006-07 Jyoti Ranjan Roy ……………………………..............................……….……Appellant Block Ac-155, Sector-1, Salt Lake City, Kolkata-700064. [Pan: Adlpr2179P] Vs. Dcit, Circle-49(1), Kolkata.............…..….…..….........……........……...…..…..Respondent

revise the appeal and the application for condonation of delay. After making the necessary changes and adding the necessary documents, the instant petition and the appeal were filed on May 1, 2024 after a delay of 5174 days. 34. Your petitioner states that he has at all times acted in a bona fide manner and that the instant delay