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121 results for “reassessment”+ Section 69Cclear

Sorted by relevance

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Key Topics

Section 147153Section 148152Addition to Income84Section 143(3)77Section 6861Section 69C58Section 26346Reassessment40Reopening of Assessment37Section 250

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 4(1), KOLKATA vs. SENDOZ COMMERCIALS PRIVATE LIMITED, KOLKATA

The appeal of the revenue is hereby dismissed

ITA 28/KOL/2025[2017]Status: DisposedITAT Kolkata30 Apr 2025

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.28/Kol/2025 Assessment Year: 2017-18 Acit, Central Circle-4(1), Kolkata ………………………………….…..……Appellant Vs. Sendoz Commercials Pvt. Ltd…………..……...........……........……...…..…..Respondent 644, Marshall House, 25, Strand Road, Kol-1. [Pan: Aagcs5174E] C.O. No.12/Kol/2025 (Arising Out Of I.T.A. No.28/Kol/2025) Assessment Year: 2017-18 Sendoz Commercials Pvt. Ltd …………..………….………………..….…..Cross-Objector 644, Marshall House, 25, Strand Road, Kol-1. [Pan: Aagcs5174E] Vs. Acit, Central Circle-4(1), Kolkata.............................……........……...…..…..Respondent Appearances By: Shri A. K. Tulsyan, Fca & Deepak Mudhra, Aca, Appeared On Behalf Of The Assessee. Shri Prabhakar Prakash Ranjan, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : April 30, 2025 Date Of Pronouncing The Order : April 30, 2025 Order Per Sonjoy Sarma: The Revenue Has Filed An Appeal & The Assessee Has Filed The Corresponding Cross-Objection Against The Same Order Dated 27.08.2024 By The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As The ‘Cit(A)’] Relating To Assessment Year 2017-18. 2. At The Outset, The Registry Has Informed That There Is A Delay Of 37 Days In Filing The Present Appeal. The Revenue Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case.

Section 115BSection 133(6)Section 143(2)Section 143(3)

Showing 1–20 of 121 · Page 1 of 7

35
Section 148A28
Condonation of Delay26
Section 148
Section 69C

reassessment proceedings, the Assessing Officer observed that the assessee had made substantial payment to M/s Tanishi Commotrade Pvt. Ltd. The Assessing Officer sought explanation regarding the identity of the party and genuineness of the transaction. The assessee submitted that it had received 1,18,00,000/- during the F.Y 2015-16 relevant to A.Y. 2016-17. The excess payment

DCIT, CIRCLE-12(1), KOLKATA, KOLKATA vs. M/S DOTEX MERCHANDISE PVT. LTD., KOLKATA

In the result, appeal of the Revenue is dismissed and the cross objections are also dismissed as infructuous

ITA 1602/KOL/2016[2010-11]Status: DisposedITAT Kolkata03 May 2019AY 2010-11

Bench: Shri A. T. Varkey, Jm & Dr. A. L. Saini, Am]

Section 133(6)Section 142(1)Section 143(1)Section 147Section 148Section 68

reassesses any income chargeable to tax, which has escaped assessment for any assessment year, with respect to which he had "reason to believe" to be so, then only, in addition, he can also put to tax, the other income, chargeable to tax, which has escaped assessment. and which has come to his notice subsequently, in the course of proceedings under

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

ITA 222/KOL/2025[2015-16]Status: DisposedITAT Kolkata24 Jul 2025AY 2015-16

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

Section 143(2)Section 144BSection 147Section 148Section 148ASection 250Section 69C

Section 69C of the Act is liable to be deleted. XV. FOR THAT the appellant craves indulgence to add, amend, alter and/or modify the Grounds of Appeal on or before the hearing of this appeal.” 2.2 The Revenue has raised the following grounds before the ITAT: “Whether the Ld. CIT(A) has erred in law as well

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

ITA 1946/KOL/2024[2015-2016]Status: DisposedITAT Kolkata24 Jul 2025AY 2015-2016

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

Section 143(2)Section 144BSection 147Section 148Section 148ASection 250Section 69C

Section 69C of the Act is liable to be deleted. XV. FOR THAT the appellant craves indulgence to add, amend, alter and/or modify the Grounds of Appeal on or before the hearing of this appeal.” 2.2 The Revenue has raised the following grounds before the ITAT: “Whether the Ld. CIT(A) has erred in law as well

M/S. AJANTA MERCHANTS PVT. LTD.,KOLKATA vs. I.T.O., WARD-8(1), KOLKATA, KOLKATA

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

ITA 608/KOL/2022[2011-2012]Status: DisposedITAT Kolkata28 Mar 2023AY 2011-2012

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(1)Section 143(3)Section 147Section 148

reassessment proceeding was set aside. The initial view was that failure to issue notice is an irregularity, which is curable when subsequently the law is well settled that it being an inherent defect is not curable. To the same effect are the decisions in Principal Commissioner of Income Tax-vs-Jai Shiv Shankar Traders Pvt. Ltd. 383 ITR 448 (Delhi

M/S. AJANTA MERCHANTS PVT. LTD.,KOLKATA vs. I.T.O., WARD - 8(1), KOLKATA, KOLKATA

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

ITA 606/KOL/2022[2009-2010]Status: DisposedITAT Kolkata28 Mar 2023AY 2009-2010

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(1)Section 143(3)Section 147Section 148

reassessment proceeding was set aside. The initial view was that failure to issue notice is an irregularity, which is curable when subsequently the law is well settled that it being an inherent defect is not curable. To the same effect are the decisions in Principal Commissioner of Income Tax-vs-Jai Shiv Shankar Traders Pvt. Ltd. 383 ITR 448 (Delhi

M/S. AJANTA MERCHANTS PVT. LTD.,KOLKATA vs. I.T.O., WARD-8(1), KOLKATA, KOLKATA

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

ITA 607/KOL/2022[2010-2011]Status: DisposedITAT Kolkata28 Mar 2023AY 2010-2011

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(1)Section 143(3)Section 147Section 148

reassessment proceeding was set aside. The initial view was that failure to issue notice is an irregularity, which is curable when subsequently the law is well settled that it being an inherent defect is not curable. To the same effect are the decisions in Principal Commissioner of Income Tax-vs-Jai Shiv Shankar Traders Pvt. Ltd. 383 ITR 448 (Delhi

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

In the result, the appeal is allowed

ITA 2241/KOL/2018[2010-11]Status: DisposedITAT Kolkata28 Feb 2019AY 2010-11

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)

For Appellant: Shri S.S. Surana, FCA, ld. ARFor Respondent: Shri C.J. Singh, JCIT, ld. Sr.DR
Section 143(3)Section 69

69C in respect of bogus purchases ­ Whether on facts, impugned addition made by Assessing Officer was to be confirmed· Held, yes [para 8] [In favour of revenue. g. It must also be stated here that in Commissioner of Income Tax vs NR Portfolio Pvt Ltd on 22 November, 2013, the Hon'ble Delhi High court has held ..... "The Assessing Officer

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

In the result, the appeal is allowed

ITA 2242/KOL/2018[2010-11]Status: DisposedITAT Kolkata28 Feb 2019AY 2010-11

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)

For Appellant: Shri S.S. Surana, FCA, ld. ARFor Respondent: Shri C.J. Singh, JCIT, ld. Sr.DR
Section 143(3)Section 69

69C in respect of bogus purchases ­ Whether on facts, impugned addition made by Assessing Officer was to be confirmed· Held, yes [para 8] [In favour of revenue. g. It must also be stated here that in Commissioner of Income Tax vs NR Portfolio Pvt Ltd on 22 November, 2013, the Hon'ble Delhi High court has held ..... "The Assessing Officer

PARSAN BROTHERS,KOLKATA vs. DCIT, CIRCLE 36, , KOLKATA

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

ITA 795/KOL/2025[2013-2014]Status: DisposedITAT Kolkata03 Sept 2025AY 2013-2014

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 148Section 250Section 69C

reassessment was done and the income was enhanced to ₹1.10 Crore against which another appeal was filed, which I.T.A. No.: 795/KOL/2025 Assessment Year: 2013-14 Parsan Brothers. is pending before the Ld. CIT(A). This is the 3rd assessment made in which addition has been made under section 69C

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

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

ITA 664/KOL/2022[2013-14]Status: DisposedITAT Kolkata09 May 2023AY 2013-14

Bench: Sri Sanjay Garg & Dr. Manish Borad

Section 147Section 250Section 69ASection 69C

reassessment proceeding under section 147 of the Income Tax Act, 1961. 3. BECAUSE the Ld. CIT(A) has erred in law and on facts in holding that AO has rightly rejected the request for cross examination of the witness. 4. BECAUSE the Ld. CIT(A) has erred in law and on facts in sustaining the addition of Rs. 16000/- made

ACIT, CIRCLE-7(1), KOLKATA, KOLKATA vs. SAWANSUKHA JEWELLERS PRIVATE LIMITED, KOLKATA

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

ITA 1615/KOL/2024[2018-2019]Status: DisposedITAT Kolkata17 Mar 2025AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Sawansukhajewellers Acit, Circle-7(1), Private Limited 5Th Floor, Aaykar Bhavan, P-7, Chowringhee Square, 4Th Floor, 9, Camac Street, Vs. Kolkata-700069, Kolkata-700017, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aafcs2477R Co No. 32/Kol/2024 (Airing Out Of The Ita No. 1615/Kol/2024 For A.Y. 2018-19) Sawansukhajewellers Acit, Circle-7(1), Private Limited 5Th Floor, Aaykar Bhavan, P-7, 4Th Floor, 9, Camac Street, Chowringhee Square, Vs. Kolkata-700017, Kolkata-700069, West Bengal West Bengal (Appellant) (Respondent) Assessee By : Shri Akkal Dudhwewala, Ar Revenue By : Shri Kapil Mondal, Dr Date Of Hearing: 03.03.2025 Date Of Pronouncement : 17.03.2025

For Appellant: Shri Akkal Dudhwewala, ARFor Respondent: Shri Kapil Mondal, DR
Section 133(6)Section 142(1)Section 143Section 143(3)Section 148

69C read with section 115BBE. The total income was computed at Rs 31,96,08,034/-, includingthe income as per the original assessment order and the addition of unexplained expenditure. The assessment ITA No. 1615/KOL/2024 & CO 32/KOL/2024 SawansukhaJewellers Private Limited; A.Y. 2018-19 proceedings resulted in the addition of potentially non-genuine purchases to the total income of the assessee

JIGNESH DESAI,KOLKATA vs. ITO, WARD-35(2), KOLKATA, KOLKATA

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

ITA 2205/KOL/2016[2010-11]Status: DisposedITAT Kolkata14 Jun 2017AY 2010-11

Bench: Hon’Ble Sri A.T.Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No. 2205/Kol/2016 Assessment Year : 2010-11 Jignesh Desai , -Vs.- I.T.O., Ward-35(2) Kolkata Kolkata [Pan : Afepd 5066 Q] (Respondent) (Appellant) For The Appellant : Shri Miraj D.Shah, Advocate For The Respondent : Shri Vijyendra Kumar, Addl. Cit Date Of Hearing : 06.06.2017. Date Of Pronouncement : 14.06.2017. Order

For Appellant: Shri Miraj D.Shah, AdvocateFor Respondent: Shri Vijyendra Kumar, Addl. CIT
Section 133(6)Section 143(2)Section 143(3)Section 147Section 148

section 69C In respect of bogus purchases - Whether on facts, Impugned addition made by Assessing Officer was to be confirmed - Held, yes [para 8] [In favour of revenue Overall from the facts and -circumstances emanating in the case, I find myself agreeable with the findings of the Ld AO, and therefore sustain the action of addition of Rs.3

M D DIESEL SPARES,HOWRAH vs. ITO, WARD-47, KOLKATA

In the result, the appeal of the assessee stands allowed

ITA 1430/KOL/2023[2012-2013]Status: DisposedITAT Kolkata03 May 2024AY 2012-2013

Bench: Shri Sanjay Garg & Rajesh Kumari.T.A No.1430/Kol/2023 Assessment Year: 2012-13 M D Diesel Spares………..………………………… ........................……Appellant 7/12, Kings Road, Howrah-711101. [Pan: Aakfm7649F] Vs. Ito, Ward-47(2), Kolkata..................…................…........……...…..…..Respondent Appearances By: Shri A. K. Tibrewal & Saurabh Gupta, Ar, Appeared On Behalf Of The Appellant. Shri Prabir Gupta Choudhury, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 26, 2024 Date Of Pronouncing The Order : May 03, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 28.10.2023 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’). 2. The Assessee In This Appeal Has Agitated Against The Addition Of Rs.18,85,520/- Made By The Assessing Officer U/S 69C Of The Act On Account Of Bogus Purchases. 3. The Brief Facts Of The Case Are That The Assessee Firm Is Involved In The Business Of Spare Parts Of The Machinery. The Assessee Firm For The Year Under Consideration Filed Its Return Of Income Declaring A Total Income Of Rs.45,150/-. The Said Return Was Processed U/S 143(1) Of The

Section 143(1)Section 147Section 250Section 271(1)(c)Section 69C

reassessment proceedings, the assessee submitted various documents such as bills, VAT returns, purchase inputs etc. The assessee also claimed that the entire payments were made through banking channel. However, in respect of the delivery transport challan, the assessee explained that these were spare parts of the machinery and were delivered to the assessee via ‘Hand Cart’. However, the Assessing Officer

M/S. DIACH CHEMICALS & PIGMENTS PRIVATE LIMITED,HOWRAH vs. PR. CIT (CENTRAL), KOLKATA - 2,, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 697/KOL/2025[2018-19]Status: DisposedITAT Kolkata25 Jul 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.697/Kol/2025 Assessment Year: 2018-19 M/S Diach Chemicals & Pigments Pvt. Ltd.………....Appellant Nh-6, Jaladhulagori Dhulaghar Industrial Park, Howrah-711302. [Pan: Aaccd1101A] Vs. Pcit, Central-2, Kolkata…..……………..………………….…..... Respondent Appearances By: Shri Sunil Surana, Fca Appeared On Behalf Of The Appellant. Shri Raja Sengupta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 22, 2025 Date Of Pronouncing The Order : July 25, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 29.03.2025 Passed By The Ld. Principal Commissioner Of Income Tax (Pcit), Kolkata, Under Section 263 Of The Income Tax Act, 1961 For The Assessment Year 2018-19. 2. Brief Facts Of The Case The Assessee Fled Its Return Of Income For The Assessment Year 2018-19 Declaring Total Income Of Rs.3,24,05,910/-. The Case Was Selected For Scrutiny & Assessment Was Completed Under Section 143(3) Of The Act On 23.04.2021 Determining Assessed Income At Rs.4,75,81,150/-. Subsequently, Pursuant To A Search & Seizure Operation Under Section 132 Of The Act In The Case Of The Diach Group Conducted On 07.12 2021 & Subsequent Dates, The Assessing Officer Reopened The Case Under Section 147 & Passed A Reassessment Order Dated 28.03 2023. In The Reassessment Order, The Ao Made An Addition Of Rs.96,84,5467/- On Account Of Bogus Purchases Under

Section 132Section 143(3)Section 147Section 263Section 69C

reassessment order, the AO made an addition of Rs.96,84,5467/- on account of bogus purchases under I.T.A. No.697/Kol/2025 M/s Diach Chemicals & Pigments Pvt. Ltd section 69C

DCIT, CENTRAL CIRCLE - 2(1), KOLKATA, KOLKATA vs. M/S. M D GARMENTS PVT. LTD., , KOLKATA

In the result, the appeal of the revenue as well as cross- objection of the assessee are dismissed

ITA 2146/KOL/2017[2009-10]Status: DisposedITAT Kolkata20 Jun 2018AY 2009-10

Bench: Shri P.M. Jagtap, Am] I.T.A. No. 2146/Kol/2017 Assessment Year: 2009-10 D.C.I.T, Central Cir – 2(1) Kolkata.........................................................................Appellant 3Rd Floor,Aayakar Bhawan Poorva, E.M. By Pass, 110, Shantipally, Kolkata – 700107 M/S. M.D. Garments Pvt. Ltd. …………………………………………………………………Respondent 156, M.G. Road, 1St Floor, Kolkata – 700 007 [Pan : Aadcm 5555 C] C.O. No. 38/Kol/2018 (Arising Out Of Ita No. 2146/Kol/2017) Assessment Year: 2009-10 M/S. M.D. Garments Pvt. Ltd. ……………………………………………………………Cross-Objector 156, M.G. Road, 1St Floor, Kolkata – 700 007 [Pan : Aadcm 5555 C] D.C.I.T, Central Cir – 2(1) Kolkata....................................................................Respondent 3Rd Floor,Aayakar Bhawan Poorva, E.M. By Pass, 110, Shantipally, Kolkata – 700107 Appearances By: Shri Robin Choudhury, Addl. Cit Appearing On Behalf Of The Revenue Shri R.P. Agarwal, Sr. Counsel & Shri Nirav Sheth, Aca Appearing On Behalf Of The Assessee Date Of Concluding The Hearing : May 25, 2018 Date Of Pronouncing The Order : June 20, 2018 Order Per P.M. Jagtap, Am This Appeal Is Preferred By The Revenue Against The Order Of Ld. Cit (A) – 20, Kolkata Dated 18.07.2017 & The Same Is Being Disposed Of Along With The Cross-Objection Filed By The Assessee Being C.O. No. 38/Kol/2018. 2 I.T.A. No. 2146/Kol/2017 & C.O. No. 38/Kol/2018 Assessment Year 2009-10 M/S. M.D. Garments Pvt. Ltd.

Section 139Section 143(1)Section 143(3)Section 147Section 148Section 68Section 69C

69C. In support of its case on the preliminary issue relating to validity of assessment under section 143(3)/147, a detailed written submission was filed by the assessee before the Ld. CIT(A) placing reliance on various judicial pronouncements. After reproducing the said written submission on page no 3 to 15 of his impugned order

SETHI FINMART (P) LTD,KOLKATA vs. PCIT-1, KOLKATA

In the result, appeal of the assessee is allowed

ITA 165/KOL/2021[2011-12]Status: DisposedITAT Kolkata18 Oct 2022AY 2011-12

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2011-12 Sethi Finmart (P) Ltd. Pr. Commissioner Of Income- C/O Subash Agarwal & Tax, Kolkata-1 Associates, Advocates, Vs. Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata-700 069. (Pan:Aaecs0188E) (Appellant) (Respondent) Present For: Appellant By : Shri Siddarth Agarwal, Advocate Respondent By : Shri Sudipta Guha, Cit, Dr Date Of Hearing : 25.08.2022 Date Of Pronouncement : 18.10.2022

For Appellant: Shri Siddarth Agarwal, AdvocateFor Respondent: Shri Sudipta Guha, CIT, DR
Section 133(6)Section 147Section 148Section 263Section 68Section 69C

reassessment proceedings were initiated after taking due approval from the competent authority. In this case, Ld. AO noted from the accounts of the assessee that it had derived profits of ₹83,76,790/- from commodities transaction through the client code – 1153 by trading through MEMBER/broker of NMCE namely Ratna Kamal Holdings Pvt. Ltd., Broker code number –CL0263. Ld. AO stated

MRS. PREMLATA TEKRIWAL ,KOLKATA vs. PRINCIPAL CIT - 10, KOLKATA , KOLKATA

In the result, all the appeals of these assessees are allowed

ITA 1129/KOL/2018[2009-10]Status: DisposedITAT Kolkata14 Jan 2021AY 2009-10

Bench: Sri J. Sudhakar Reddy & Sri A. T. Varkey

Section 139Section 147Section 263Section 271(1)(c)

section 69C of the Act there is no scope for partial disallowance under the said provision. After considering the reply of the assessee at para 10 of this order he ordered as follows: 10. Accordingly, in view of the facts and circumstances of the case as stated above, and also respectfully following the judgments cited above particularly that

MRS. PREMLATA TEKRIWAL ,KOLKATA vs. PRINCIPAL CIT - 10, KOLKATA , KOLKATA

In the result, all the appeals of these assessees are allowed

ITA 1131/KOL/2018[2011-12]Status: DisposedITAT Kolkata14 Jan 2021AY 2011-12

Bench: Sri J. Sudhakar Reddy & Sri A. T. Varkey

Section 139Section 147Section 263Section 271(1)(c)

section 69C of the Act there is no scope for partial disallowance under the said provision. After considering the reply of the assessee at para 10 of this order he ordered as follows: 10. Accordingly, in view of the facts and circumstances of the case as stated above, and also respectfully following the judgments cited above particularly that

BINOD KUMAR TEKRIWAL ,KOLKATA vs. PRINCIPAL CIT - 10, KOLKATA , KOLKATA

In the result, all the appeals of these assessees are allowed

ITA 1133/KOL/2018[2011-12]Status: DisposedITAT Kolkata14 Jan 2021AY 2011-12

Bench: Sri J. Sudhakar Reddy & Sri A. T. Varkey

Section 139Section 147Section 263Section 271(1)(c)

section 69C of the Act there is no scope for partial disallowance under the said provision. After considering the reply of the assessee at para 10 of this order he ordered as follows: 10. Accordingly, in view of the facts and circumstances of the case as stated above, and also respectfully following the judgments cited above particularly that