In the result, the appeal of the Revenue is allowed and the Cross Objection filed by the assessee is dismissed
Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Girish Agrawali.T.A. No. 546/Kol/2023) Assessment Year: 2012-2013 Assistant Commissioner Of Income Tax,....Appellant Central Circle-2(1), Kolkata, Aayakar Bhawan Poorva, 3Rd Floor, 110, Shanti Pally, Kolkata-700107 -Vs.- Shalimar Hatcheries Ltd.,......................Respondent 46C, Chowringhee Road, Park Street, 17Th Floor, Everest House, Kolkata-700071 [Pan: Aadcs6537J] - A N D - C.O. No. 13/Kol/2023 (In I.T.A. No. 546/Kol/2023) Assessment Year: 2012-2013 Shalimar Hatcheries Ltd.,..................Cross Objector 46C, Chowringhee Road, Park Street, Kolkata-700071 [Pan: Aadcs6537J] -Vs.- Assistant Commissioner Of Income Tax,....Respondent Central Circle-2(1), Kolkata, Aayakar Bhawan Poorva, 110, Shanti Pally, Kolkata-700107 Appearances By: Shri P.P. Barman, Addl. Cit, Appeared On Behalf Of The Revenue
reassessment u/s147. Similarly, it has also been held in various judicial pronouncements that the reasons recorded for initiating the proceedings u/s147, have to speak for themselves. The reasons must provide a live link to the formation of the belief that income had escaped assessment. The reasons cannot keep the assessee guessing fur the reasons for initiating the proceedings u/s147. These