Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2012-13 Reachasia……………………..……………..............................……….……Appellant 109/28, Hazra Road, Kol- 700026. [Pan: Aagrf2430K] Vs. Dcit/Acit, Circle-29, Kolkata…………………………...……...…..…..Respondent Appearances By: Shri Manish Tiwari, Fca, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 01, 2025 Date Of Pronouncing The Order : September 03, 2025 Order Per Rajesh Kumar: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 12.02.2025 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 of the assessee u/s 147 can only be made subject to the satisfaction of the condition envisaged under 1st proviso to section 147 of the Act which states an assessment has been made u/s 143(3), the reopening u/s 147 of the Act can only be made if the income has escaped assessment due to non-disclosure of true