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

Section 68 of the Income Tax Act, 1961. 13. That the appellant craves to leave, add, amend or 13 adduce any of the grounds of appeal during the course of appellate proceedings.” A. We shall first take up ITA No. 179/KOL/2025 for AY 2011-12 for adjudication. 3. Brief facts of the case are that the assessee company was engaged

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

Section 68 of the Income Tax Act, 1961. 13. That the appellant craves to leave, add, amend or 13 adduce any of the grounds of appeal during the course of appellate proceedings.” A. We shall first take up ITA No. 179/KOL/2025 for AY 2011-12 for adjudication. 3. Brief facts of the case are that the assessee company was engaged

THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(2), GANGTOK, GANGTOK SIKKIM vs. SIKKIM STATE COOPERATIVE SUPPLY AND MARKETING FEDERATION LIMITED , GANGTOK SIKKIM

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

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

reassessed. (4) Subject to the provisions of sub-section (6), where the source of any receipt, deposit or investment in any assessment year is claimed to be an amount added to income or deducted while computing loss, as the case may be, in the assessment of such person in any year prior to the assessment year in which such receipt

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

JCIT(OSD), CIRCLE - 8, KOLKATA, KOLKATA vs. M/S. SICPA INDIA PVT. LTD., KOLKATA

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

Bench: Shri Mahavir Singh, Jm & Shri Waseem Ahmed, Am]

96,450/-. Assessment was completed under section 143(3) of Act on 21.03.2005 assessing total income at Rs.14,85,56,420/-. In the instant case the assessee company entered into a collaboration agreement with foreign company for manufacture of security printing inks for Bank notes and for other securities and the right to sell such products under the terms

ITO, WARD 10(2), KOLKATA, KOLKATA vs. ALEX TRADECOM PRIVATE LIMITED, KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2197 & 2198/Kol/2024 Assessment Years: 2013-14 & 2014-15 Ito, Ward-10(2), Kolkata…………..…………………………….…….……Appellant Vs. Alex Tradecom Pvt. Ltd…………..……………….………...……...…..…..Respondent 4, Ratan Sarkar Garden Street, Burrabazar, Kol- 700069. [Pan: Aajca6146P] Appearances By: Smt. Madhumita Das, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Akshay Ringasia, Ca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Revenue For The Assessment Years 2013-14 & 2014-15 Against Separate Orders Dated 05.08.2024 & 26.07.2024 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’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. Both The Appeals Have Been Filed By The Revenue With Delays Of 38 Days. The Revenue Has Filed Separate Affidavits For Condonation Of The Delays. After Considering The Reasons Cited In The Affidavits For Condonation Of Delay, We Find That The Reasons Are Valid And

reassessment notice Section 151 of the new regime does not prescribe a time limit within which a specified authority has to grant sanction. Rather, it links up the time limits with the jurisdiction of the authority to grant sanction Section 151 (ii) of the new regime prescribes a higher level of authority if more than three years have elapsed from

ITO, WARD-10(2), KOLKATA, KOLKATA vs. ALEX TRADECOM PRIVATE LIMITED, KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2197 & 2198/Kol/2024 Assessment Years: 2013-14 & 2014-15 Ito, Ward-10(2), Kolkata…………..…………………………….…….……Appellant Vs. Alex Tradecom Pvt. Ltd…………..……………….………...……...…..…..Respondent 4, Ratan Sarkar Garden Street, Burrabazar, Kol- 700069. [Pan: Aajca6146P] Appearances By: Smt. Madhumita Das, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Akshay Ringasia, Ca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Revenue For The Assessment Years 2013-14 & 2014-15 Against Separate Orders Dated 05.08.2024 & 26.07.2024 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’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. Both The Appeals Have Been Filed By The Revenue With Delays Of 38 Days. The Revenue Has Filed Separate Affidavits For Condonation Of The Delays. After Considering The Reasons Cited In The Affidavits For Condonation Of Delay, We Find That The Reasons Are Valid And

reassessment notice Section 151 of the new regime does not prescribe a time limit within which a specified authority has to grant sanction. Rather, it links up the time limits with the jurisdiction of the authority to grant sanction Section 151 (ii) of the new regime prescribes a higher level of authority if more than three years have elapsed from

SANJAY KUMAR BHUTRA,KOLKATA vs. ITO, WARD 44(2),, KOLKATA

In the result, all the appeals of the Revenue are dismissed

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2013-14 Sanjay Kumar Bhutra………...……………………….……….……….……Appellant Geeta Katra, 1, Mullick St., 1St Floor, Burrabazar, Kol- 7.. [Pan: Ahspb7216J] Vs. Ito, Ward-44(2), Kolkata………………………………….....……...…..…..Respondent Appearances By: Shri S. K. Pransukha, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 04, 2025 Date Of Pronouncing The Order : September 18, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 19.12.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

reassessment notice Section 151 of the new regime does not prescribe a time limit within which a specified authority has to grant sanction. Rather, it links up the time limits with the jurisdiction of the authority to grant sanction Section 151 (ii) of the new regime prescribes a higher level of authority if more than three years have elapsed from

DCIT,CIRCLE-1, KOLKATA, KOLKATA vs. M/S CHEVIOT CO. LTD., KOLKATA

In the result, the appeals of revenue are dismissed and COs of assessee are allowed

Bench: Shri Mahavir Singh, Jm & Shri M. Balaganesh, Am]

reassessment and initiation of proceeding u/s. 147 of Income Tax Act, 1961. b) That the original assessment having been completed u/s. 143(3), initiation of re- assessment proceeding beyond four years period was invalid in law without establishing the failure on the part of the assessee company to disclose fully & truly all material facts for its assessment for the relevant

GOAL ORIENTED TRADE LINK PVT. LTD.,,KOLKATA vs. ITO, WARD 2(1),, KOLKATA

In the result, the appeal of the assessee is allowed

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

96 taxmann.com 104 (Calcutta)/[2018] 409 ITR 132 (Calcutta)[22-06-2018], wherein it has held as under:- “7. Section 148 of the Act permits the issuance of a notice in certain circumstances when it is discovered that income has escaped assessment and sub-section (1) thereof mandates a return to be filed upon an assessee being served a notice

BHARGAB ENGINEERING WORKS,HOWRAH vs. PCIT, CENTRAL KOLKATA 2, , KOLKATA

In the result, the appeal of the assessee is dismissed

Bench: Shri George Mathan & Shri Rakesh Mishra

96,97,730/- after making an addition of Rs.1,69,565/- to the income assessed under section 143(3) vide order dated 21.04.2021 at Rs.95,28,160/-. The ld. PCIT, Central Circle-2, Kolkata thereafter, examined the record and observed certain discrepancies from the from the assessment record and the order under section 147 r.w.s. 143(3) dated

DCIT, CIRCLE - 11(1) , KOLKATA vs. M/S. G.S. ATWAL & COMPANY (ENGINEERS) PVT. LTD., , KOLKATA

In the result, both the appeals of the Revenue and Cross

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumar

section 68 on account of unexplained cash credits. 7. On appeal, it was submitted by the assessee that reopening of assessment is not in accordance with law. The same information was available with the Department during the original assessment proceedings and no addition was made. The ld. 1st Appellate Authority in a detailed order running into around 96 pages accepted

DCIT, CIRCLE - 48, KOLKATA, KOLKATA vs. SANJAY JAISWAL, HOWRAH

In the result, the cross objection of the assessee is allowed , appeals of the assessee and revenue are dismissed as infructuous

Bench: : Shri N.V.Vasudevan & Shri M. Balaganesh

sections (1) [, (1A), (1B)] and (2) shall not apply to the following classes of assessments, reassessments and recomputations which may, 96

VINAYAK TRADEVIN PVT. LTD., ,KOLKATA vs. ITO, WARD 2(1), , KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri Sonjoy Sarmavinayak Tradevin Pvt. Ltd. Vs Ito, Ward-2(1), Kolkata 41, B B Ganguly Street, 2Nd Floor, Room No13B, Kol-12. Pan No. : Aaccv8710B (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri P. K. Himmatsinghka, Ar राज"व क" ओर से /Revenue By : Shri S. B. Chakraborthy, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 22/09/2025 घोषणा क" तार"ख/Date Of Pronouncement : 08/12/2025

reassessment proceeding under section 147 of the Act. The Hon’ble Jurisdictional Calcutta High Court in CIT v. Oberoi Hotels Pvt. Ltd. 2018) 96

SEN FERRO ALLOYS (P) LTD.,KOLKATA vs. A.C.I.T., CC - 4(3), KOLKATA, KOLKATA

In the result, both appeals of the assessee are allowed

96 of the paper book which reads as follows:-\nINCOME TAX DEPARTMENT\n9\nITA No.2358&2359/KOL/2024\nGOVERNMENT OF INDIA\nMINISTRY OF FINANCE\nINCOME TAX DEPARTMENT\nOFFICE OF THE ASSISTANT\nCOMMISSIONER OF INCOME TAX\nCENTRAL CIR 4(3), KOLKATA\nTo,\nSEN FERRO ALLOYS PVT LTD\n21, ROOM NO. 206, HEMANT BASU SARANI KOLKATA\nKOLKATA 700001, West Bengal\nIndia\nPAN:\n Assessment

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.

section 142(1) and duly examined by Assessing Officer in original assessment - notices and order for issue of notice set aside - Urban Homes Realty vs. Union of India (Born.) ITR 459 /Page 96. C. Reassessment

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.

section 142(1) and duly examined by Assessing Officer in original assessment - notices and order for issue of notice set aside - Urban Homes Realty vs. Union of India (Born.) ITR 459 /Page 96. C. Reassessment

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.

section 142(1) and duly examined by Assessing Officer in original assessment - notices and order for issue of notice set aside - Urban Homes Realty vs. Union of India (Born.) ITR 459 /Page 96. C. Reassessment

D.C.I.T.,CIRCLE-11(1), KOLKATA vs. TURTLE LTD., HOWRAH

In the result, the appeal of the revenue is dismissed

Bench: Shri A. T. Varkey, Jm & Shri Girish Agrawal, Am]

section 142(1) of the Act framed the reassessment at a sum of Rs. 23,91,96,130/- by making