IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM ITA No.2179/KOL/2025 (Assessment Year: 2011-12)

Shree Krishna Gyanodaya ACIT, Central Circle 4(3)

Flour Mills Pvt. Ltd.

Aaykar Bhawan Poorva

15^th Floor, 46C, Chowringhee Vs. 110, Kolkata-700107, Road, Everest House, Kolkata-

West Bengal

700071, West Bengal (Appellant) (

Respondent)

PAN No. AAHCS8774P Assessee by : Shri S.K. Tulsiyan, AR Revenue by : Shri Sanat Kumar Raha, DR Date of hearing: 01.12.2025 Date of pronouncement: 31.12.2025

O R D E R

Per Rajesh Kumar, AM:

This is an appeal preferred by the assessee against the order of the Commissioner of Income-tax (Appeals), Kolkata-27(hereinafter referred to as the “Ld. CIT(A)”] dated 30.07.2025 for the AY 2011-12.

2. The common issue raised in ground no.1 to 4 of assessee’s appeal is against the order ld. CIT (A) upholding the reopening of assessment u/s 147 read with section 148 of the Income-tax Act, 1961 (the Act) which was made by the ld. AO invalidly without satisfying the necessary pre-conditions for reopening of assessment and accordingly, the assessee prayed that the reopening of assessment may kindly be quashed.

2.1. T