M/S. SHAKAMBHARI ISPAT & POWER LTD.,KOLKATA vs. DCIT, CC - 3(3),, KOLKATA

153C has been discontinued and new scheme has been put in\nplace which required the AO to re-open certain numbers of assessment\nyears. The Id DR submitted the provisions of Section 148 of the Act after\nsearch are analogous to the provisions to the provision of Section 153A of\nthe Act which was prevalent and applicable till now where

M/S. SHAKAMBHARI ISPAT & POWER LTD., ,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), , KOLKATA

153C has been discontinued and new scheme has been put in\nplace which required the AO to re-open certain numbers of assessment\nyears. The Id DR submitted the provisions of Section 148 of the Act after\nsearch are analogous to the provisions to the provision of Section 153A of\nthe Act which was prevalent and applicable till now where

M/S. SHAKAMBHARI ISPAT & POWER LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), , KOLKATA

153C has been discontinued and new scheme has been put in\nplace which required the AO to re-open certain numbers of assessment\nyears. The Id DR submitted the provisions of Section 148 of the Act after\nsearch are analogous to the provisions to the provision of Section 153A of\nthe Act which was prevalent and applicable till now where

URVASHI SAREES PVT. LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 11(1), , KOLKATA

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

Bench: ITAT, Kolkata were collected and prepared | | 18.01.2025 | 2nd Appeal was filed |

disallowing the entire purchase amount and to restrict it to Rs. 27,73,218/-? Whether the Ld. CIT(A) has erred in law as well as in facts in ignoring the judicial principles laid down in the matter of N.K. Protein Ltd. Vs. DCIT (84txman.com 195) (SC). That the appellant craves leave to add any new ground or alter

PRAMOD LAKRA DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), KOLKATA, KOLKATA vs. URVASHI SAREES PVT. LTD, KOLKATA

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

Bench: ITAT, Kolkata were collected and prepared | | 18.01.2025 | 2nd Appeal was filed |

disallowing the entire purchase amount and to restrict it to Rs. 27,73,218/-? Whether the Ld. CIT(A) has erred in law as well as in facts in ignoring the judicial principles laid down in the matter of N.K. Protein Ltd. Vs. DCIT (84txman.com 195) (SC). That the appellant craves leave to add any new ground or alter

D.C.I.T., CC - 3(1),, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

153C has been discontinued and new scheme has been put in\nplace which required the AO to re-open certain numbers of assessment\nyears. The Id DR submitted the provisions of Section 148 of the Act after\nsearch are analogous to the provisions to the provision of Section 153A of\nthe Act which was prevalent and applicable till now where

M/S. SHAKAMBHARI ISPAT & POWER LTD., ,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), , KOLKATA

153C has been discontinued and new scheme has been put in\nplace which required the AO to re-open certain numbers of assessment\nyears. The Id DR submitted the provisions of Section 148 of the Act after\nsearch are analogous to the provisions to the provision of Section 153A of\nthe Act which was prevalent and applicable till now where

M/S. SHAKAMBHARI ISPAT & POWER LTD.,,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), , KOLKATA

153C has been discontinued and new scheme has been put in\nplace which required the AO to re-open certain numbers of assessment\nyears. The Id DR submitted the provisions of Section 148 of the Act after\nsearch are analogous to the provisions to the provision of Section 153A of\nthe Act which was prevalent and applicable till now where

DEPUTY COMMISSIONER OF INCOME TAX, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

153C has been discontinued and new scheme has been put in\nplace which required the AO to re-open certain numbers of assessment\nyears. The Id DR submitted the provisions of Section 148 of the Act after\nsearch are analogous to the provisions to the provision of Section 153A of\nthe Act which was prevalent and applicable till now where

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3.1, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

153C has been discontinued and new scheme has been put in\nplace which required the AO to re-open certain numbers of assessment\nyears. The Id DR submitted the provisions of Section 148 of the Act after\nsearch are analogous to the provisions to the provision of Section 153A of\nthe Act which was prevalent and applicable till now where

DEPUTY COMMISSIONER OF INCOME TAX, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

153C has been discontinued and new scheme has been put in\nplace which required the AO to re-open certain numbers of assessment\nyears. The Id DR submitted the provisions of Section 148 of the Act after\nsearch are analogous to the provisions to the provision of Section 153A of\nthe Act which was prevalent and applicable till now where

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 3(1),, KOLKATA vs. SHAKAMBHARI ISPAT & POWER LIMITED, KOLKATA

153C has been discontinued and new scheme has been put in\nplace which required the AO to re-open certain numbers of assessment\nyears. The Id DR submitted the provisions of Section 148 of the Act after\nsearch are analogous to the provisions to the provision of Section 153A of\nthe Act which was prevalent and applicable till now where

M/S. SHAKAMBHARI ISPAT & POWER LTD., ,KOLKATA vs. DCIT, CENTRAL CIRCLE 3(3), KOLKATA

Appeals of the assessee are partly allowed and\nappeals of the revenue are dismissed

153C has been discontinued and new scheme has been put in\nplace which required the AO to re-open certain numbers of assessment\nyears. The Id DR submitted the provisions of Section 148 of the Act after\nsearch are analogous to the provisions to the provision of Section 153A of\nthe Act which was prevalent and applicable till now where

M.A. FINANCIAL SERVICES PVT. LTD.,,KOLKATA vs. ITO, WARD 4(1),, KOLKATA

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

Bench: Shri Pradip Kumar Choubey & Shri Sanjay Awasthiassessment Year: 2015-16 M. A Financial Services Pvt. Ltd.……………………….……….……….……Appellant 2, Lal Bazaar Street, 1St Floor, Kol-700001.. [Pan: Aaccm0481E] Vs. Ito, Ward-4(1), Kolkata…….…………………………….....……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Ar, Appeared On Behalf Of The Appellant. Shri Praveen Kishore, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 09, 2025 Date Of Pronouncing The Order : October 17, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.05.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2015–16. 2. Brief Facts Of The Case Of The Assessee Are That The Assessee Filed Its Return Of Income For The A.Y 2015-16 U/S 139 Of The Act On 20.07.2015 Declaring Total Income Of Rs.9,647/-. The Said Return Was Processed U/S 143(1) Of The Act. Later On, Based On Information Received Through Itba Software Under The Head High Risk Transaction Case Notice U/S 148A(B) Of The Act Was Issued & Finally Notice U/S 148 Of The Act Was Issued On 13.07.2022. In Response, The Assessee Filed Return On 02.11.2021 Declaring Total Income Of Rs.9,647. Assessment Was Made Under Sec. 147 M. A Financial Services Pvt. Ltd Read With Section 144B Of The Act On 24.05.2023 Determining Total Income Of Rs.6,55,31,471/- Inter-Alia Making Following Addition:

Disallowance of expenses claimed under the head of salary and wages of Rs.51,15,500/-. 3. Addition on account of unexplained money of Rs.85,55,000 u/s. 69A of the Act. 3. Aggrieved by the said order, the assessee preferred appeal before the ld. CIT(A) wherein the appeal of the assessee has been dismissed on account of non-compliance

SUMITA ROY CHOWDHURY,KOLKATA vs. I.T.O., WARD - 48(1),, KOLKATA

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

Bench: Shri Pradip Kumar Choubey & Shri Sanjay Awasthiassessment Year: 2015-16 M. A Financial Services Pvt. Ltd.……………………….……….……….……Appellant 2, Lal Bazaar Street, 1St Floor, Kol-700001.. [Pan: Aaccm0481E] Vs. Ito, Ward-4(1), Kolkata…….…………………………….....……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Ar, Appeared On Behalf Of The Appellant. Shri Praveen Kishore, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 09, 2025 Date Of Pronouncing The Order : October 17, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.05.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2015–16. 2. Brief Facts Of The Case Of The Assessee Are That The Assessee Filed Its Return Of Income For The A.Y 2015-16 U/S 139 Of The Act On 20.07.2015 Declaring Total Income Of Rs.9,647/-. The Said Return Was Processed U/S 143(1) Of The Act. Later On, Based On Information Received Through Itba Software Under The Head High Risk Transaction Case Notice U/S 148A(B) Of The Act Was Issued & Finally Notice U/S 148 Of The Act Was Issued On 13.07.2022. In Response, The Assessee Filed Return On 02.11.2021 Declaring Total Income Of Rs.9,647. Assessment Was Made Under Sec. 147 M. A Financial Services Pvt. Ltd Read With Section 144B Of The Act On 24.05.2023 Determining Total Income Of Rs.6,55,31,471/- Inter-Alia Making Following Addition:

Disallowance of expenses claimed under the head of salary and wages of Rs.51,15,500/-. 3. Addition on account of unexplained money of Rs.85,55,000 u/s. 69A of the Act. 3. Aggrieved by the said order, the assessee preferred appeal before the ld. CIT(A) wherein the appeal of the assessee has been dismissed on account of non-compliance

NEZONE TUBES LIMITED,KOLKATA vs. DCIT, CIRCLE 1(1), KOLKATA

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

Bench: Shri George Mathan & Shri Rakesh Mishra

DISALLOWED.” ITA Nos.: 179 & 180/KOL/2025 AYs: 2011-12 & 2015-16 Nezone Tubes Limited. 5. Aggrieved with the order of the Ld. CIT(A), the assessee has filed the appeal before the Tribunal. 6. Rival contentions were heard and the submissions made have been examined. It was submitted by the Ld. AR that the original assessment in this case was made

NEZONE TUBES LIMITED,KOLKATA vs. DCIT, CIRCLE 1(1), KOLKATA

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

Bench: Shri George Mathan & Shri Rakesh Mishra

DISALLOWED.” ITA Nos.: 179 & 180/KOL/2025 AYs: 2011-12 & 2015-16 Nezone Tubes Limited. 5. Aggrieved with the order of the Ld. CIT(A), the assessee has filed the appeal before the Tribunal. 6. Rival contentions were heard and the submissions made have been examined. It was submitted by the Ld. AR that the original assessment in this case was made

RAJA UDYOG (P) LTD.,24-PARGANAS (N) vs. ACIT, CC-4(3), KOL, KOLKATA

In the result, I.T.(SS)A. No

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.944/Kol/2024 Assessment Years: 2017-18 Raja Udyog (P) Ltd…..…………….....……………………....………....Appellant Sukchar Girja, 16F, Barrackpore Trunk Road, 24 Parganas (N), W.B – 700115. [Pan: Aaccr0764P] Vs. Acit, Cc-4(3), Kolkata…...................................................…..…..... Respondent I.T.(Ss)A. No.43/Kol/2024 Assessment Year: 2017-18 Raja Udyog (P) Ltd…..…………….....……………………....………....Appellant Sukchar Girja, 16F, Barrackpore Trunk Road, 24 Parganas (N), W.B – 700115. [Pan: Aaccr0764P] Vs. Acit, Cc-4(3), Kolkata…...................................................…..…..... Respondent I.T.(Ss)A. No.44/Kol/2024 Assessment Year: 2018-19 Raja Udyog (P) Ltd…..…………….....……………………....………....Appellant Sukchar Girja, 16F, Barrackpore Trunk Road, 24 Parganas (N), W.B – 700115. [Pan: Aaccr0764P] Vs. Acit, Cc-4(3), Kolkata…...................................................…..…..... Respondent Appearances By: Shri Rajeeva Kumar, Advocate, Appeared On Behalf Of The Appellant. Shri Rakesh Kr. Das, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 29, 2024 Date Of Pronouncing The Order : July 30, 2024

section 153C of the Income Tax Act, 1961 is bad in law and therefore need to be quashed. 2. That under the facts and in the circumstances of the case, the Ld. CIT(A) erred in confirming the addition of Rs.7,32,646/- for delayed deposit of employees' contributions to PF and ESI under sec. 36(1)(va) r.w.s. 2