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

Date of Hearing: 21.08.2024

May It Please To Your Honour

1. In this case, the case is re-opened on the basis of reasons for reopening recorded on 23.03.2018. The same is reproduced herewith and is also forming part of Paperbook - II filed before your Honour.

2. On perusal of the reasons, the following undisputed facts and discrepancies are pointed out which can be considered as different limbs of argument against re-opening of assessment and issuance of