ORDER

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 30.10.2025 for the AY 2011-12.

2. The issue raised in ground no.1 and 4 is against the order of ld. CIT (A) upholding the reopening of assessment u/s 147 read with section 148 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) which is based upon the borrowed satisfaction and therefore, the same is invalid and same may be quashed.

2.1. The facts in brief are that the assessee filed the return of income on 27.08.2011, showing total income at ₹65,917/-. The assessee is engaged in the business of basmati rice production and wind power generation. A search action u/s 132(1) of the Act was conducted on the assessee on 27.3.2014 and accordingly the assessment was framed u/s 153A/143(3) of the Act vide order dated 27.03.2014, assessing the total income at ₹4,50,773/-. Thereafter, the case of