IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH,KOLKATA SHRI RAJESH KUMAR, ACCOUNTANT MEMBER PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER (Assessment Year 2019-2020)

DCIT, Central Circle-4(3), Kolkata, Aayakar Bhawan Poorva, 110, Shantipally, Kolkata - 700107…..…...……………....Appellant vs.

Nawal Kumar Kanodia, 702, Luv Kush Tower, Exhibition Road, Patna, Bihar - 800001 [PAN: AHHPK6268J]…..…...…………….... Respondent Appearances by:

Assessee represented by : Manish Rastogi, AR Department represented by : Altaf Hussain, Addl. CIT, Sr. DR Date of concluding the hearing : 25.02.2026 Date of pronouncing the order : 06.03.2026

O R D E R

Per Rajesh Kumar, AM The present appeal filed by the revenue arises from order dated

12.04.2025passed u/s 250of the Income Tax Act, 1961 (hereafter “the Act”) by the Ld. Commissioner of Income Tax (Appeals)-Kolkata-

27[hereafter “the Ld.CIT(A)].

2. The issue raised in Ground No. 1 is against the order of Ld.CIT(A) annulling the assessment framed u/s 147/143(3) of the Act dated 29.03.2024 by treating the same as void-ab-initio without properly appreciate that the facts of the case and the legal validity of the reassessment proceedings.

3. The facts in brief are that the assess