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

26 IST, prior to the expiry of the 3 stipulated time period provided in the notice for submissions, thereby violating the principles of natural justice and denying a reasonable opportunity to be heard. 4. The Hon'ble Commissioner of Income Tax (Appeals) erred both in law and on facts by failing to adjudicate the ground that the addition 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

26 IST, prior to the expiry of the 3 stipulated time period provided in the notice for submissions, thereby violating the principles of natural justice and denying a reasonable opportunity to be heard. 4. The Hon'ble Commissioner of Income Tax (Appeals) erred both in law and on facts by failing to adjudicate the ground that the addition made

ACIT, CIRCLLE-34, KOLKATA vs. SUBHAS KUMAR KEDIA, KOLKATA

In the result, appeal of the revenue is dismissed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1677/Kol/2024 (नििाारण वर्ा / Assessment Year : 2016-2017) Acit, Circle-34, Kolkata Vs Subhas Kumar Kedia, 41, N.S.Road, Kolkata Pan No. :Afnpk 9669 M (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Ms. Shreya Loyalka, Ar राजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 21/01/2025 घोषणा की तारीख/Date Of Pronouncement : 17/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Revenue Against The Order Dated 05.06.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2016-2017, On The Following Grounds Of Appeal :- I) That On The Facts & In The Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order U/S.148A(D) & All Subsequent Proceedings. Ii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Failed To Acknowledge The Fact That The Assesse Had Not Expressed Any Grievance Against The Validity Of Order U/S 148A(D) By Moving Any Writ Petition Which Should Have Been Done In Case Of Any Grievance After Getting The Sald Order U/S.148A(D). Iii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order When The Ld. Cit(A) Has No Jurisdiction To Deal With The Question Whether The 148A(D) Order Was Passed Validly Or Properly As An Order U/S.148A(D) Is Not An Appealable Order Before Ld. Cit(A) As Per Section 246A.

26-5- 2022 under section 148A (b) of the Act to the petitioner. 3.3 The petitioner filed a reply dated 14-6-2022 qua the said notice. 3.4 Thereafter, the revenue passed an order under section 148A (d) of the Act dated 29-7-2022 holding that income amounting to Rs. 4,37,56,000/-had escaped assessment. A consequential

JERMEL'S ACCADEMY,SILIGURI vs. I.T.O., WARD - 1(4), , SILIGURI

In the result, the appeal filed by the assessee is allowed as per the directions mentioned above

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

26-09-2023] 8.1 In the case of Genius Education Society (supra) the Hon'ble Tribunal has held as under: “■ Admittedly, the reopening in the instant case was resorted to for the reason that the assessee had been refused approval under section 10(12C)(vi) and had not filed its return of income. It is not disputed that the assessee

HARSH COMTRADE PVT LTD,SURAT vs. INCOME TAX OFFICER, WARD 5(4), KOLKATA

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri George Mathanआयकर अपील सं/Ita No.225/Kol/2024 (नििाारण वर्ा / Assessment Year :2012-2013) Harsh Comtrade Private Limited, Vs Ito, Ward-5(4), Kolkata 1/A, Stuti Apartment, Near Ashok Panhouse, City Light, Surat, Gujarat Pan No. :Aabcg 8847 C (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Mehul Shah, Ar नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri S.B. Chakraborthy, Addl. Cit-Sr.Dr सुनवाई की तारीख / Date Of Hearing : 01/07/2025 घोषणा की तारीख/Date Of Pronouncement : 01/07/2025 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 28.12.2023, Passed In Din & Order No.Itba/Nfac/S/250/2023-24/1059161646(1) For The Assessment Year 2012-2013. 2. Shri Mehul Shah, Ld. Ar Appeared On Behalf Of The Assessee & Shri S.B.Chakraborthy, Ld.Sr. Dr Appeared On Behalf Of The Revenue. 3. At The Time Of Hearing, Ld. Ar Submitted That He Has Filed Written Submissions Before The Tribunal Which Has Been Placed In The Paper Book At Pages 90 To 104 Which Reads As Follows :- Before Income Tax Appellate Tribunal, Kolkata - 'Smc' Bench In The Case Of Harsh Comtrade Pvt. Ltd Sub: Written Submission For A.Y. 2012-13 Ref: Assessee'S Appeal No. 225/Kol/2024 Date Of Hearing: 21.08.2024 May It Please To Your Honour 1. In This Case, The Case Is Re-Opened On The Basis Of Reasons For Reopening Recorded On 23.03.2018. The Same Is Reproduced

10 notice was issued under section 148. Setting out the reasons, for the belief that income had escaped assessment. Those judicial decisions had held that when the assessment was sought to be reopened on the ground that income had escaped assessment on a certain issue, the Assessing Officer could not make an assessment or reassessment on another issue which came

SATISH KUMAR BIRDIKA,KOLKATA vs. I.T.O., WARD - 49(1), KOLKATA, KOLKATA

In the result, the appeal filed by the Assessee is hereby allowed

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

26,30,613/-. 3. Aggrieved by the said order, the assessee preferred an appeal before the Ld. CIT(A) wherein the appeal of the assessee has been dismissed as there was non- compliance before the Ld. CIT(A). Being aggrieved and dissatisfied the assessee preferred an appeal before us. 4. In course of submission, the ld. A.R has raised legal

DCIT, CC-1(4), KOLKATA, KOLKATA vs. KKALPANA INDUSTRIES INDIA LIMITED, KOLKATA

In the result, appeal of the revenue is dismissed

Bench: Shri George Mathan & Shri Sanjay Awasthiआयकर अपील सं/Ita No.452/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2016-2017) Dcit, Cc-1(4), Kolkata Vs Kkalpana Industries India Ltd. 2B, Pretoria Street, Middleton Row, Kolkata-700071 Pan No. :Aabck 2239 D (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Shri S.K.Tulsiyan, Advocate & Ms. Puja Somani, Ca रधजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 24/06/2025 घोषणा की तारीख/Date Of Pronouncement : 25/06/2025 आदेश / O R D E R Per George Mathan, Jm : This Is An Appeal Filed By The Revenue Against The Order Dated 13.11.2024, Passed By The Ld. Cit(A), Kolkata-20, Passed In Din & Order No.Itba/Apl/S/250/2024-25/1070338584(1), For The Assessment Year 2016-2017. 2. Shri P.N.Barnwal, Ld.Cit-Dr Appeared On Behalf Of The Revenue & Shri S.K.Tulsiyan, Advocate With Ms. Puja Somani, Ca, Appeared On Behalf Of The Assessee. 3. A Perusal Of The Appeal Record, We Find That The Appeal Of The Revenue Has Been Filed Belatedly By 28 Days. In This Regard, The Revenue Has Filed An Application For Condonation Of Delay Stating Sufficient Reasons Which Are Plausible & Not Found To Be False. Thus, The Delay Of 28 Days In Filing The Appeal Is Condoned & Appeal Is Admitted For Hearing.

reassessment proceedings has been laid down is reproduced below: "When a notice under section 148 of the Income-tax Act, 1961, is issued, the proper course of action is to file the return and, if he so desires, to seek reasons for issuing the notices. The assessing officer is bound to furnish reasons within a reasonable time. On receipt

INCOME TAX OFFICER, KOLKATA vs. SHIVRASHI VANIJYA PRIVATE LIMITED, KOLKATA

In the result, the appeal is hereby treated as allowed

10 challenge the reopening for reopening reasons. It is seen that the notice u/s 148 was initially issued in this case on 29/06/2021 and it is covered by the decision of the Hon'ble Supreme Court in the case of Union of India v/s Ashish Agarwal [2022] 444 ITR 1 (SC) and Union of India v/s Rajeev Bansal

KIPPY ENGINEERING PVT. LTD.,KOLKATA vs. ACIT, CC - 3(4), KOLKATA

In the result, the appeal of the assessee is allowed

reassessment\nproceedings were wrongly initiated vide notice dated 14.03.2019 u/s. 148 and that the\nmandatory approval of the sanctioning authority i.e. the principal commissioner of\nincome tax as required to be obtained u/s. 151 of the act is invalid.\n(b) That the sanctioning authority i.e. the principal commissioner of income tax has not\napplied his mind while granting

VRINDA ENGINEERS PVT. LTD. ,KOLKATA vs. ACIT,C.C-1(1),KOLKATA. , KOLKATA

In the result, both the appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. Nos. 1274/Kol/2023 Assessment Year: 2012-2013 Vrinda Engineers Pvt. Ltd.,.......................Appellant C/O. Subash Agarwal & Associates, Advocates, Siddha Gibson, 1, Gibson Lane, Suite-213, 2Nd Floor, Kolkata-700069 [Pan: Aaacv9131E] -Vs.- Principal Commissioner Of Income Tax,....Respondent Central-1, Kolkata, Aayakar Bhawan Poorva, 110, Shantipally, E.M. Bypass, Kolkata-700107 -A N D- I.T.A. Nos. 1232/Kol/2023 Assessment Year: 2012-2013 Vrinda Engineers Pvt. Ltd.,.......................Appellant C/O. Subash Agarwal & Associates, Advocates, Siddha Gibson, 1, Gibson Lane, Suite-213, 2Nd Floor, Kolkata-700069 [Pan: Aaacv9131E] -Vs.- Assistant Commissioner Of Income Tax,....Respondent Central Circle-1(1), Kolkata, Aayakar Bhawan Poorva, 110, Shantipally, E.M. Bypass, Kolkata-700107

10 to 23 of the paper book. He took us through this decision and submitted that in paragraph no. 9 of this order, while taking cognizance of the facts, Hon’ble Court has observed that one of the stands taken by the assessee before the ITAT was that reassessment proceeding is invalid, therefore, there could not be any 263 order

VRINDA ENGINEERS PVT. LTD. ,KOLKATA vs. PCIT, CER-1, KOLKATA. , KOLKATA

In the result, both the appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. Nos. 1274/Kol/2023 Assessment Year: 2012-2013 Vrinda Engineers Pvt. Ltd.,.......................Appellant C/O. Subash Agarwal & Associates, Advocates, Siddha Gibson, 1, Gibson Lane, Suite-213, 2Nd Floor, Kolkata-700069 [Pan: Aaacv9131E] -Vs.- Principal Commissioner Of Income Tax,....Respondent Central-1, Kolkata, Aayakar Bhawan Poorva, 110, Shantipally, E.M. Bypass, Kolkata-700107 -A N D- I.T.A. Nos. 1232/Kol/2023 Assessment Year: 2012-2013 Vrinda Engineers Pvt. Ltd.,.......................Appellant C/O. Subash Agarwal & Associates, Advocates, Siddha Gibson, 1, Gibson Lane, Suite-213, 2Nd Floor, Kolkata-700069 [Pan: Aaacv9131E] -Vs.- Assistant Commissioner Of Income Tax,....Respondent Central Circle-1(1), Kolkata, Aayakar Bhawan Poorva, 110, Shantipally, E.M. Bypass, Kolkata-700107

10 to 23 of the paper book. He took us through this decision and submitted that in paragraph no. 9 of this order, while taking cognizance of the facts, Hon’ble Court has observed that one of the stands taken by the assessee before the ITAT was that reassessment proceeding is invalid, therefore, there could not be any 263 order

MADHUBAN DEALERS PVT. LTD. PRESENTLY KNOWN AS MADHUBAN DEALERS LLP,KOLKATA vs. PCIT-13, KOLKATA

In the result, the appeal of assessee allowed

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

reassessment order in the light of the Ld Pr. CIT order dated 27.07.2016, the assessee company got amalgamated with M/s. Nihon Impex Private Ltd. We note that it was the result of the scheme of amalgamation filed before the Hon’ble NCLT which was duly sanctioned vide order dated 21.12.2018. With this amalgamation made effective from 01.04.2017, the assessee company

ITO, WARD-5(1), KOLKATA vs. M/S BPO FINANCE AND INVESTMENTS PVT LTD, KOLKATA

In the result, the appeal of the revenue stands dismissed

Bench: Shri Sanjay Garg & Rajesh Kumari.T.A No.99/Kol/2022 Assessment Year: 2008-09 Ito, Ward-5(1), Kolkata……..........................................................……Appellant Vs. M/S Bpo Finance & Investments Pvt. Ltd. .……........……..…..…..Respondent R No.54,5/1, Clive Row (2Nd Floor), Kolkata-1. [Pan: Aaccb5328F] Appearances By: Shri Manish Tiwari, Ar Appeared On Behalf Of The Appellant. Shri Vijay Kumar, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : May 15, 2023 Date Of Pronouncing The Order : July 04, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Revenue Against The Order Dated 10.09.2020 Of The Commissioner Of Income Tax (Appeals)-13, Kolkata (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Revenue Originally Has Taken The Following Grounds Of Appeal: “1. Whether On The Facts & In The Circumstances Of The Case, Ld, Cit(A) Was Justified In The Quashing The Addition Of Rs. 1,85,000,00/- Made By The Assessing Officer On Account Of Share Capital & Premium In The Course Assessment In Absence Of Identity Of The Creditors, Genuineness & Creditworthiness Of The Entire Transactions. 2. Whether On The Facts & In The Circumstances Of The Case, Ld, Cit(A) Was Justified In The Quashing The Addition Of Rs. 1,85,00,000/-Made By The Assessing Officer Where No Personal Attendance Was Made By Any Director Of The Share Allottee Companies During The Course Of Assessment Proceedings & As Such Identity & Creditworthiness Of The Creditors & Genuineness Of Transactions Could Not Be Verified.

10 Date of order 29.03.2016 f) The appellant's case was transferred from New Delhi to Kolkata 01.04.2009 the order u/s 127 of the Act with regard to the same form part of our paper book. The appellant's case was transferred u/s 127 of the Act, the effect of such transfer is that all the proceedings of the appellant

ITO, WARD-6(2), KOLKATA, KOLKATA vs. RAGHUVIR RETAILERS PVT. LTD., KOLKATA

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyi.T.A. No. 1129/Kol/2025 Assessment Year: 2012-2013 Income Tax Officer,………………..……………..Appellant Ward-6(2), Kolkata, Aayakar Bhawan, 6Th Floor, P-7, Chowringhee Square, Kolkata-700069 -Vs.- Raghuvir Retailers Pvt. Limited,.……….....Respondent Mandawa Shikhar, 151, Sarat Bose Road, Kolkata-700026 [Pan:Aaecr8231M] Appearances By: Shri S.B. Chakraborthy, Sr. D.R., Appeared On Behalf Of The Revenue Shri Abhisek Bansal, A.R., Appeared On Behalf Of The Assessee

26 of assessee company computation of income of 27 27 assessee-company IT return of assessee 28 50 ITR acknowledgment of 51 51 assessee-company 8. 23.07.2019 Notice issued u/s 142(1) 52 54 9. 20.08.2019 Assessee filed reply in 55 55 response to notice issued u/s 142(1) 10. 05.09.2019 Notice issued u/s 142(1) 56 57 10.09.2019 Assessee

PURPLE SUPPLIERS PVT. LTD.,SURAT, GUJRAT vs. A.C.I.T., CIRCLE - 5(1), KOLKATA, KOLKATA

In the result, all the three appeal for AYs 2011-12 to 2013-14 of the assessee are allowed

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.757 To 759/Kol/2022 Assessment Years: 2011-12 To 2013-14 Purple Suppliers Pvt. Ltd. ………. Appellant (Pan: Aafcp2218P) Vs. Asstt. Commissioner Of Income Tax, Circle-5(1), Kolkata. ………… Respondent Appearances By: Shri Anil Kochar, Advocate Appeared For Appellant. Shri Subhendu Datta, Cit, Dr Appeared For Respondent. Date Of Concluding The Hearing : 28.05.2024 Date Of Pronouncing The Order : 26.08.2024 Order Per Manish Borad: The Captioned Appeals Filed At The Instance Of The Assessee Pertaining To The Assessment Years (In Short “Ay”) 2011-12 To 2013-14 Are Directed Against The Separate Orders Passed U/S 250 Of The Income Tax Act, 1961 (In Short The “Act”) By Ld. Commissioner Of Income-Tax, Appeal, National Faceless Appeal Centre (Nfac), Delhi [In Short Ld. “Cit(A)”] Dated 03.11.2022 Arising Out Of The Separate Assessment Orders U/S 143(3)/147 Of The Act By Acit, Circle-5(1), Kolkata Dated 31.12.2018. Since Grounds Of Appeal Raised In These Appeals Are Common & Facts Are Identical, Except Variance In Amount, With The Consent Of Both The Parties, We Proceed To Dispose Of All These Appeals By This Consolidated Order For The Sake Of Brevity & Convenience.

10. Hon’ble Bombay High Court in the case of Prashant S. Joshi (2010) 230 CTR 232 (Bom) has observed ‘The AO must have reasons to believe that such is the case (i.e. any income chargeable to tax has escaped assessment for a particular year) before he proceeds to issue notice u/s 147”. In other words, reasons have

PURPLE SUPPLIERS PVT. LTD.,SURAT, GUJRAT vs. A.C.I.T., CIRCLE - 5(1), KOLKATA, KOLKATA

In the result, all the three appeal for AYs 2011-12 to 2013-14 of the assessee are allowed

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.757 To 759/Kol/2022 Assessment Years: 2011-12 To 2013-14 Purple Suppliers Pvt. Ltd. ………. Appellant (Pan: Aafcp2218P) Vs. Asstt. Commissioner Of Income Tax, Circle-5(1), Kolkata. ………… Respondent Appearances By: Shri Anil Kochar, Advocate Appeared For Appellant. Shri Subhendu Datta, Cit, Dr Appeared For Respondent. Date Of Concluding The Hearing : 28.05.2024 Date Of Pronouncing The Order : 26.08.2024 Order Per Manish Borad: The Captioned Appeals Filed At The Instance Of The Assessee Pertaining To The Assessment Years (In Short “Ay”) 2011-12 To 2013-14 Are Directed Against The Separate Orders Passed U/S 250 Of The Income Tax Act, 1961 (In Short The “Act”) By Ld. Commissioner Of Income-Tax, Appeal, National Faceless Appeal Centre (Nfac), Delhi [In Short Ld. “Cit(A)”] Dated 03.11.2022 Arising Out Of The Separate Assessment Orders U/S 143(3)/147 Of The Act By Acit, Circle-5(1), Kolkata Dated 31.12.2018. Since Grounds Of Appeal Raised In These Appeals Are Common & Facts Are Identical, Except Variance In Amount, With The Consent Of Both The Parties, We Proceed To Dispose Of All These Appeals By This Consolidated Order For The Sake Of Brevity & Convenience.

10. Hon’ble Bombay High Court in the case of Prashant S. Joshi (2010) 230 CTR 232 (Bom) has observed ‘The AO must have reasons to believe that such is the case (i.e. any income chargeable to tax has escaped assessment for a particular year) before he proceeds to issue notice u/s 147”. In other words, reasons have

PURPLE SUPPLIERS PVT. LTD.,SURAT, GUJRAT vs. A.C.I.T., CIRCLE - 5(1), KOLKATA, KOLKATA

In the result, all the three appeal for AYs 2011-12 to 2013-14 of the assessee are allowed

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. Nos.757 To 759/Kol/2022 Assessment Years: 2011-12 To 2013-14 Purple Suppliers Pvt. Ltd. ………. Appellant (Pan: Aafcp2218P) Vs. Asstt. Commissioner Of Income Tax, Circle-5(1), Kolkata. ………… Respondent Appearances By: Shri Anil Kochar, Advocate Appeared For Appellant. Shri Subhendu Datta, Cit, Dr Appeared For Respondent. Date Of Concluding The Hearing : 28.05.2024 Date Of Pronouncing The Order : 26.08.2024 Order Per Manish Borad: The Captioned Appeals Filed At The Instance Of The Assessee Pertaining To The Assessment Years (In Short “Ay”) 2011-12 To 2013-14 Are Directed Against The Separate Orders Passed U/S 250 Of The Income Tax Act, 1961 (In Short The “Act”) By Ld. Commissioner Of Income-Tax, Appeal, National Faceless Appeal Centre (Nfac), Delhi [In Short Ld. “Cit(A)”] Dated 03.11.2022 Arising Out Of The Separate Assessment Orders U/S 143(3)/147 Of The Act By Acit, Circle-5(1), Kolkata Dated 31.12.2018. Since Grounds Of Appeal Raised In These Appeals Are Common & Facts Are Identical, Except Variance In Amount, With The Consent Of Both The Parties, We Proceed To Dispose Of All These Appeals By This Consolidated Order For The Sake Of Brevity & Convenience.

10. Hon’ble Bombay High Court in the case of Prashant S. Joshi (2010) 230 CTR 232 (Bom) has observed ‘The AO must have reasons to believe that such is the case (i.e. any income chargeable to tax has escaped assessment for a particular year) before he proceeds to issue notice u/s 147”. In other words, reasons have

MCLEOD RUSSEL INDIA LTD.,KOLKATA vs. PCIT - 2, KOLKATA, KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

26,052/- beyond the due date iv) Unaccounted profit from the sale of tea - Rs.3,61,55,620/- manufactured from purchased tea leaves. 2 Mcleod Russel India Ltd. AY 2016-17 4. Accordingly, assessment was framed vide order dated 17.03.2022 u/s. 147 read with 144B of the Act. Thereafter, the Ld. Pr. CIT on perusal of the assessment record noticed

SEIKH ABDUL SABIR GOLAHAT NIMTALA MASJID,BURDWAN vs. CIT(A), BURDWAN

In the result, the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 309/Kol/2023 Assessment Year: 2006-2007 Seikh Abdul Sabir, Golahat Nimtala Masjid,……………………………Appellant P.O. Sripally, Dist. Purba Bardhaman-713101, W.B. [Pan:Azaps9812M] -Vs.- Commissioner Of Income Tax (Appeals),…..Respondent Burdwan, Near Court Compound, Burdwan-713101 Appearances By: Shri Soumitra Choudhury, Advocate & Shri Rajeeva Kumar, Advocate, Appeared On Behalf Of The Assessee Shri Arun Kanti Dutta, Addl. Cit, Sr. D.R. Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 03, 2024 Date Of Pronouncing The Order: July 04, 2024 O R D E R

26,978/-. Original assessment was made on 31.12.2008 under section 143(3) of the Income Tax Act. The ld. Assessing Officer has determined the taxable income at Rs.8,21,119/-. The assessment thereafter was reopened by issuance of a notice under section 148 of the Income Tax Act and a reassessment order under section 147 read with section