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INCOME TAX APPELLATE TRIBUNAL (KOLKATA BENCH)
Shri George Mathan, J
HARSH COMTRADE PVT LTD SURAT – Appellant
Versus
INCOME TAX OFFICER WARD 5(4) KOLKATA – Respondent
| Table of Content |
|---|
| 1. the appeal is against an order from the cit. (Para 1 , 2) |
| 2. arguments against the reopening of assessment based on suspicion. (Para 3 , 4 , 5) |
| 3. inquiry conducted by the revenue is inadequate. (Para 6 , 7 , 8) |
| 4. legal precedents supporting the argument against reopening. (Para 9 , 10 , 11) |
| 5. legal thresholds for valid reopening procedures. (Para 12 , 13 , 14) |
| 6. absence of credible information leads to quashing of reopening. (Para 15) |
आदेश/ORDER
This is an appeal filed by the assessee against the order of the ld CIT(A), National Faceless Appeal Centre (NFAC), Delhi, dated 28.12.2023, passed in DIN & Order No.ITBA/NFAC/S/250/2023-24/1059161646(1) for the assessment year 2012-2013.
2. Shri Mehul Shah, ld. AR appeared on behalf of the assessee and Shri S.B.Chakraborthy, ld.Sr. DR appeared on behalf of the revenue.
3. At the time of hearing, ld. AR submitted that he has filed written submissions before the Tribunal which has been placed in the paper book at pages 90 to 104 which reads as follows :-
Before Income Tax Appellate Tribunal, Kolkata - 'SMC' Bench
In the case of Harsh Comtrade Pvt. Ltd
Sub: Written Submission for A.Y. 2012-13
Ref: Assessee's Appeal No. 225/KOL/2024
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