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:

section 144B of the Act on 24.05.2023 determining total income of Rs.6,55,31,471/- inter-alia making following addition: 1. Addition on account of unexplained money of Rs.5,18,51,321/-. u/s. 69A of the Act. 2. Disallowance of expenses claimed under the head of salary and wages of Rs.51,15,500/-. 3. Addition on account of unexplained money

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.

69A of the Act) and addition of Rs. 2,12,87,500/- (u/s 68 of the Act). Aggrieved with this, the assessee has approached the Ld. CIT(A) were also he could not succeed on either of the issues. 2 K.Y.S. Sponge Iron Pvt. Ltd. 1.1 Thereafter, the assessee is seen to have approached the ITAT with several grounds

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.

reassessment notice for the A.Y.2016-17 was to be dealt as under :- Fresh notice u/s. 148 can be issued with approval of the specified authority under clause (a) of sub-section (1) of New Section 149 since AY 2016-17 is within the period of three years from the end of relevant assessment year. Specified authority u/s.151

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 69B or the value of any bullion, jewellers or other valuable article referred to in section 69A

ACIT, INTERNATIONAL TAXATION CIR.-1(2), KOLKATA , KOLKATA vs. MAHABIR PRASAD GUPTA , KOLKATA

In the result, the appeal filed by the Revenue and the Cross

Bench: Dr. Manish Borad & Sonjoy Sarma

Section 57(3) of the Act is applicable only for expenses incurred to earn the income, therefore, the alleged interest expenditure having no nexus with the interest earned during the year cannot be allowed as deduction. 9. Per contra ld. Counsel for the assessee vehemently argued referring to the paper book containing various details including cash flow statement

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND SPONGE AND IRON PRIVATE LIMITED , PATNA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect

BHAIRABLANA SAMABAY KRISHI UNNAYAN SAMITY LIMITED ,VILL- HATBELE, POST- HATBELE vs. ASSESSING OFFICER, ASSESSMENT UNIT, INCOME TAX DEPARTMENT, NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2018-19

section 69A of the Income Tax Act 1961, although there is books of accounts maintained by your assessee and the cash deposit of Rs. 61,15,617 were explained before the assessing officer, assessment unit, income tax department, with the copy of cash book for relevant dates, and also erred infact by adding Rs. 3,00,000 in respect

ADHYAM BUILDWELL PRIVATE LIMITED,NEW DELHI vs. WARD 9(1) (NFAC), KOLKATA

In the result, the appeal of the assessee is allowed for statistical\npurpose subject to above directions

sections": [ "250", "148", "148A(d)", "149", "69A" ], "issues": "Whether the reassessment proceedings were validly initiated and whether the addition made

DCIT, CENTRAL CIRCLE- 4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect

GITA SHARMA,DURGAPUR vs. I.T.O., WARD - 2(4), DURGAPUR

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

Bench: Shri George Mathan & Shri Rakesh Mishra

69A of the Act to the total income of the assessee and also an amount of ₹1,25,43,804/- was treated as undisclosed money and added to the total income of the assessee. The Ld. AO assessed the total income of the assessee at I.T.A. No.: 2267/KOL/2025 Assessment Year: 2017-18 Gita Sharma

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND SPONGE AND IRON PRIVATE LIMITED, PATNA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect

GLASSEYE TRADERS PVT. LTD.,KOLKATA vs. I.T.O., WARD - 1(1), KOLKATA, KOLKATA

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

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

69A of the Act. Admittedly, this amount was substituted for an amount of Rs. 5,57,91,000/- which was part of the reasons recorded before issuance of notice u/s 148 of the Act, as transaction from M/s. MPS Greenery Developers Ltd. 1.1. Aggrieved with this action, the appellant approached the ld. CIT(A) and one of the grounds raised

KAMALESH KUMAR TRIPATHI,KOLKATA vs. I.T.O., WARD - 52(2), KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2513/Kol/2024 Assessment Year: 2012-2013 Kamalesh Kumar Tripathi,…………….………Appellant Vishwasadan Co-Op. Housing Society, Action Area-1A, Plot No. Al/1/E/3, Flat 2B, Street No. 15, New Town, Kolkata-700156 [Pan:Abjpt4000B] -Vs.- Income Tax Officer,……………………..……...Respondent Ward-52(2), Kolkata, Bamboo Villa, Central Revenue Building, 169, A.J.C. Bose Road, Kolkata-700014 Appearances By: Shri S.K. Tulsian, A.R., Appeared On Behalf Of The Assessee Shri L.N. Dash, Addl. Cit (D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: March 12, 2025 Date Of Pronouncing The Order: May 29, 2025 O R D E R

reassess the income for the relevant assessment year and directing him to file return under section 148 in the prescribed form. The assessee complied with the notice under section 148 and filed return of income on 30.04.2019. The main allegation as per reasons recorded for reopening of assessment based on which the appellant’s case was reopened was that

ZENOM VYAPAAR PRIVATE LIMITED,KOLKATA vs. INCOME TAX OFFICER, WARD-3(1)

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

Bench: Sri Sanjay Garg & Dr. Manish Borad

section 69A of the Income Tax Act, 1961. 2. BECAUSE the Ld. CIT(A) has erred in law and on facts in not adjudicating the grounds relating to validity of initiation of reassessment

ANJU DARUKA,BURDWAN vs. ITO, WARD - 3(1),, ASANSOL

In the result, the appeal of the assessee is allowed

reassessment under Section 148 of the Act. The said approval\ncannot be granted in a mechanical manner as it acts as a linkage between the facts\nconsidered and conclusion reached. In the instant case, merely appending the phrase\n\"Yes\" does not appropriately align with the mandate of Section 151 of the Act as it fails

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED , KOLKATA

The appeal of the revenue is dismissed

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

Section 292C of the Act, the presumption is to be drawn in respect of WhatsApp transactions in the hands of the person from whose possession or control the books of accounts/ documents, etc. are found. Even the presumption u/s 292C of the Act is rebuttable when the assessee proved that he has not done any such transactions even in respect

DCIT, CENTRAL CIRCLE-4(3), KOLKATA, KOLKATA vs. BALMUKUND CEMENT & ROOFINGS PRIVATE LIMITED, KOLKATA

The appeal of the Revenue is dismissed

Section 292C of the\nAct, the presumption is to be drawn in respect of WhatsApp\ntransactions in the hands of the person from whose possession or\ncontrol the books of accounts/ documents, etc. are found. Even the\npresumption u/s 292C of the Act is rebuttable when the assessee\nproved that he has not done any such transactions even in respect