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

reassessment notice under section 148 after 1 April 2021, the Revenue would still have to look at: (i) the time limit specified under section 149 of the new regime; and (ii) the time limit for issuance of notice as extended by TOLA and its notifications. The Revenue cannot extend the operation of the old law under TOLA

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

reassessment notice under section 148 after 1 April 2021, the Revenue would still have to look at: (i) the time limit specified under section 149 of the new regime; and (ii) the time limit for issuance of notice as extended by TOLA and its notifications. The Revenue cannot extend the operation of the old law under TOLA

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 |

reassessment notice under section 148 after 1 April 2021, the Revenue would still have to look at: (i) the time limit specified under section 149 of the new regime; and (ii) the time limit for issuance of notice as extended by TOLA and its notifications. The Revenue cannot extend the operation of the old law under TOLA

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 |

reassessment notice under section 148 after 1 April 2021, the Revenue would still have to look at: (i) the time limit specified under section 149 of the new regime; and (ii) the time limit for issuance of notice as extended by TOLA and its notifications. The Revenue cannot extend the operation of the old law under TOLA

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:

reassessment notice under section 148 after 1 April 2021, the Revenue would still have to look at: (i) the time limit specified under section 149 of the new regime; and (ii) the time limit for issuance of notice as extended by TOLA and its notifications. The Revenue cannot extend the operation of the old law under TOLA

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:

reassessment notice under section 148 after 1 April 2021, the Revenue would still have to look at: (i) the time limit specified under section 149 of the new regime; and (ii) the time limit for issuance of notice as extended by TOLA and its notifications. The Revenue cannot extend the operation of the old law under TOLA

ANUPAMA VINTRADE PRIVATE LIMITED,KOLKATA vs. ITO, WARD 10(2), KOLKATA

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

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2015-16 Anupama Vintrade Pvt. Ltd..….……………………….……….……….……Appellant 77, 4Th Floor, Room 422, Elliot Road, Kol-700016.. [Pan: Aahca5675R] Vs. Ito, Ward-10(2), Kolkata….……………………………….....……...…..…..Respondent Appearances By: Shri Somnath Ghosh, Advocate, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 08.03.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Appeal Has Been Filed By The Assessee With A Delay Of 14 Days. 2. The Assessee Has Filed An Affidavit For Condonation Of The Delay. After Considering The Reasons Cited In The Affidavit For Condonation Of Delay, We Find That The Reasons Are Valid & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

reassessment notice under section 148 after 1 April 2021, the Revenue would still have to look at: (i) the time limit specified under section 149 of the new regime; and (ii) the time limit for issuance of notice as extended by TOLA and its notifications. The Revenue cannot extend the operation of the old law under TOLA

GUINESS FINANCE & LEASING PVT. LTD.,,KOLKATA vs. ITO, WARD 6(2),, KOLKATA

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

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2015-16 Guiness Finance & Leasing Pvt. Ltd..….……………….……….……….……Appellant 3Rd Floor, Baid Property, 10, Canning Street, Burra Bazar, Kol-1.. [Pan: Aabck1388B] Vs. Ito, Ward-6(2), Kolkata….……………………………….....……...…..…..Respondent Appearances By: Shri Miraj D Shah, Ar, Appeared On Behalf Of The Appellant. Shri Sandeep Lakra, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2025 Date Of Pronouncing The Order : November 13, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 16.05.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Brief Facts Of The Case Of The Assessee Are That The Assessee 2. Company Filed Its Return Of Income For The A.Y 2015-16 On 30.09.2015 Declaring Total Income Of Rs.Nil. The Said Return Was Selected For Scrutiny On The Reason That The Assessee Is The Beneficiary Of Credit Of Rs.1,28,38,232/- From Penny Stock Company M/S Steel Exchange Ltd. Notices U/S 143(2) & 142(1) Of The Act Were Issued & Thereafter, The Case Of The Assessee Reopened By Issuing Notice U/S 148 Of The Act On 14.07.2022. The Assessing Officer Passed An Ex Parte Order U/S 147 Guiness Finance & Leasing Pvt. Ltd R.W.S. 144B Of The Act On 29.05.2023 Adding Rs.1,28,38,391/- To The Total Income Of The Assessee.

reassessment notice under section 148 after 1 April 2021, the Revenue would still have to look at: (i) the time limit specified under section 149 of the new regime; and (ii) the time limit for issuance of notice as extended by TOLA and its notifications. The Revenue cannot extend the operation of the old law under TOLA

K.Y.S. SPONGE IRON PVT. LTD.,KOLKATA vs. I.T.O., WARD - 3(1),, KOLKATA

Appeal of the assessee is allowed

Bench: Any Other Issue.

reassessment notice under section 148 after 1 April 2021, the Revenue would still have to look at: (i) the time limit specified under section 149 of the new regime; and (ii) the time limit for issuance of notice as extended by TOLA and its notifications. The Revenue cannot extend the operation of the old law under TOLA

M/S PCM STRESCON OVERSEAS VENTURE LTD.,SILIGURI vs. PCIT-1, , KOLKATA

In the result, both appeal preferred by the revenue (ITA No

Bench: Shri P. M. Jagtap & Shri A. T. Varkey]

69 days and condonation petition has been filed. After considering the same and upon hearing both the sides, we condone the delay and admit the appeal for hearing. ITA No.2652/Kol/2019 & CO No. 15/Kol/2020 PCM Strescon Overseas Ventures Ltd., AY 2012-13 2. At the outset, the Ld. A.R. for the assessee Shri Akkal Dudhwewala submitted that ITA No. 2652/Kol/2019

I.T.O.,WARD-1(1), KOLKATA vs. M/S PCM STRESCON OVERSEAS VENTURE LTD., KOLKATA

In the result, both appeal preferred by the revenue (ITA No

Bench: Shri P. M. Jagtap & Shri A. T. Varkey]

69 days and condonation petition has been filed. After considering the same and upon hearing both the sides, we condone the delay and admit the appeal for hearing. ITA No.2652/Kol/2019 & CO No. 15/Kol/2020 PCM Strescon Overseas Ventures Ltd., AY 2012-13 2. At the outset, the Ld. A.R. for the assessee Shri Akkal Dudhwewala submitted that ITA No. 2652/Kol/2019

ITO, WD.9(1), KOLKATA vs. M/S MAHARAJ VINCOM PVT. LTD., KOLKATA

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.35/Kol/2021 Assessment Year: 2009-10 Ito, Ward-9(1), Kolkata……………….......................…...……………....Appellant Vs. M/S Maharaj Vincom Pvt. Ltd……............…..........................…..…..... Respondent 69, Jamunalal Bajaj Street, Kolkata- 700007. [Pan: Aafcm6496E] C.O. No.6/Kol/2023 (A/O I.T.A. No.35/Kol/2021) Assessment Year: 2009-10 M/S Maharaj Vincom Pvt. Ltd……............…..........................…....... Cross-Objector 69, Jamunalal Bajaj Street, Kolkata- 700007. [Pan: Aafcm6496E] Vs Ito, Ward-9(1), Kolkata …………..….......................…...……………....Respondent Appearances By: Shri Miraj D. Shah, Ar, Appeared On Behalf Of The Assessee. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Department. Date Of Concluding The Hearing : March 07, 2024 Date Of Pronouncing The Order : May 15, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: This Appeal By The Revenue & Corresponding Cross-Objection By The Assessee Have Been Preferred Against The Order Dated 08.09.2020 Of The Commissioner Of Income Tax (Appeals)-7, Kolkata (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’).

69, Jamunalal Bajaj Street, Kolkata- 700007. [PAN: AAFCM6496E] Vs ITO, Ward-9(1), Kolkata …………..….......................…...……………....Respondent Appearances by: Shri Miraj D. Shah, AR, appeared on behalf of the assessee. Shri Abhijit Kundu, CIT-DR, appeared on behalf of the department. Date of concluding the hearing : March 07, 2024 Date of pronouncing the order : May 15, 2024 आदेश / ORDER संजय गग", "या

ANANDA PAUL,KOLKATA vs. ACIT, CIRCLE-50, KOLKATA, KOLKATA

In the result, assessee’s appeal stands are allowed

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmedassessment Year :2007-08 Ananda Paul V/S. Acit, Circle-50, Cf-125, Salt Lake City, Manicktala Civic Centre, Kolkata-64 Uttarpan Complex, Ds- [Pan No.Afkpp 2201 D] 2&3, Kolkata-54 .. अपीलाथ" /Appellant ""यथ"/Respondent Shri S.K. Tulsiyan, Advocate अपीलाथ" क" ओर से/By Appellant Shri S. Dasagupta, Addl. Cit-Dr ""यथ" क" ओर से/By Respondent 12-02-2018 सुनवाई क" तार"ख/Date Of Hearing 20-04-2018 घोषणा क" तार"ख/Date Of Pronouncement आदेश /O R D E R Per Waseem Ahmed:- This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-Xxxii, Kolkata Dated 05.11.2014. Assessment Was Framed By Acit, Circle-50 Kolkata U/S 147/143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Vide His Order Dated 30.12.2011 For Assessment Year 2007-08. Shri, S.K. Tulsiyan, Ld. Advocate Appeared On Behalf Of Assessee & Shri S. Dasgupta, Ld. Departmental Representative Appeared On Behalf Of Revenue. 2. The Assessee Has Raised The Following Grounds Of Appeal:- “1) That On The Fats & In The Circumstances Of The Case, The Ld. Cit(A) Erred In Not Treating The Re-Assessment Proceeding U/S 143(3)/147 Of The It Act, 1961 As Invalid, Bad In Law, Unjust & Contrary To The Facts & Law. 2) That On The Facts & In Respect To The Circumstances Of Thee Case, The Ld. Cit(A) Erred In Confirming The Assessment Order Passed U/S. 143(3)/147 Of The It Act, 1961 By The Ld. Ao As Proper & Valid Without Considering The

section 147." (3) Asteroids Trading & Investment P. Ltd. vs DClT (2009) 308 lTR 190 (Bom), in the said case, it was held that since no new material brought on record, reassessment on change of opinion of officer not valid. (4) Asian Paints Ltd. vs. DCIT (2008) 308 ITR 195 (Bom), in this case, the Hon'ble High Court observed that

SMT. LAXMI DEVI CHINDALIA ,KOLKATA vs. ITO, WARD - 35(3), KOLKATA

In the result, the appeal is allowed

Bench: Hon’Ble Shri S.S. Godara, Jm] I.T.A No. 2241/Kol/2018 Assessment Year : 2010-11 Smt. Laxmi Devi Chindalia Vs. I.T.O, Ward 34(2) Pan: Acopc8728P Kolkata (Appellant) (Respondent) I.T.A No. 2242/Kol/2018 Assessment Year : 2010-11 Shri Aditya Chindalia Vs. I.T.O, Ward 34(2) Pan: Afkpc6363F Kolkata (Appellant) (Respondent)

section 69 of the Act. Apart from the above source of funds is evidenced by the payments from disclosed bank accounts. Therefore the source of investments is also properly and satisfactorily explained by the assesses. In the circumstances, We are of the view that the additions made by the AO and confirmed by CIT(A) cannot be sustained

SHRI ADITYA CHINDALIA ,KOLKATA vs. ITO, WARD - 34(2), KOLKATA

In the result, the appeal is allowed

Bench: Hon’Ble Shri S.S. Godara, Jm] I.T.A No. 2241/Kol/2018 Assessment Year : 2010-11 Smt. Laxmi Devi Chindalia Vs. I.T.O, Ward 34(2) Pan: Acopc8728P Kolkata (Appellant) (Respondent) I.T.A No. 2242/Kol/2018 Assessment Year : 2010-11 Shri Aditya Chindalia Vs. I.T.O, Ward 34(2) Pan: Afkpc6363F Kolkata (Appellant) (Respondent)

section 69 of the Act. Apart from the above source of funds is evidenced by the payments from disclosed bank accounts. Therefore the source of investments is also properly and satisfactorily explained by the assesses. In the circumstances, We are of the view that the additions made by the AO and confirmed by CIT(A) cannot be sustained

BIMLA DEVI AGRAWAL,KOLKATA vs. A.C.I.T./D.C.I.T., CIRCLE - 34, KOLKATA, KOLKATA

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

Bench: Shri George Mathan & Shri Rakesh Mishra

reassessment under this Act, where an estimate of the value of any investment referred to in section 69 or section

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

In the result, the appeal is hereby treated as allowed

Section 148A(b) of the Act on 13.06.2022. Thus, the period of limitation began running from that date. 69. As noted above, by virtue of TOLA, the AO had period of twentynine days limitation left on the date of commencement of the reassessment

ACIT, CENTRAL CIRCLE - XX, KOLKATA, KOLKATA vs. M/S. PREM LAL JAIN, KOLKATA

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

Bench: : Shri S.S. Viswanethra Ravi

69 of the Income Tax Act towards investment in shares when the assessee failed to establish the genuineness of the transactions representing inflow of funds so invested and also the identity and creditworthiness of the persons paying such amount to the assessee.” 3.2. The Learned DR vehemently supported the order of the Learned AO. In response to this, the Learned

SRI MOTILAL JAIN,KOLKATA vs. I.T.O., WARD-35(4), KOLKATA, KOLKATA

In the result, the appeals of the assessee are allowed

Bench: Shri P.M. Jagtap

69(C) of I.T. Act, therefore, attract the section 147 of the I.T. Act, 1961 for the AY 2010-11. Hence, notice u/s 148 for income escaping assessment u/s 147 of the I.T. Act, 1961 to be issued for such escapement of income”. 6. As rightly pointed out by the ld. counsel for the assessee from the reasons recorded