IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM ITA Nos. 2026 & 2027/KOL/2025 (Assessment Years: 2016-17 & 2018-19)

M/s Blackstone Overseas Pvt.

ltd. ITO, Ward 5(1)

3^rd Floor, Room No.308, 5, Aaykar Bhawan, P-7, Surendra Mohan Ghosh Sarani, Vs. chowringhee Square, Kolkata-

Dalhousie, Kolkata-700001, 700069, West Bengal West Bengal (Appellant) (

Respondent)

PAN No. AADCB6931H Assessee by : Shri Sunil Surana, AR Revenue by : Shri Pradeep Dung Dung, DR Date of hearing: 04.12.2025 Date of pronouncement: 18.12.2025

O R D E R

Per Rajesh Kumar, AM:

These are appeals preferred by the assessee against the orders of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 30.07.2025 & 23.07.2025 for the AYs 2016-17 & 2018-19 respectively.

A.Y. 2018-19 ITA No. 2027/KOL/2025

2. At the time of hearing the ld. Counsel for the assessee pressed ground no.6, which is extracted as under:-

“6. For that the ld. CIT (A) erred in confirming the order of the ld. AO when reopening of assessment itself was bad in law since approval accorded u/s 151 of the Act was not in accordance with law.”

2.1. The facts in b