2019 (9) TMI 1262

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....For the Respondent: Shri C. J. Singh, JCIT, Sr. DR ORDER Shri S.S. Viswanethra Ravi, JM: This appeal by the assessee against the order dated 21.12.2017 passed by the Commissioner of Income Tax (Appeals)-4, Kolkata ['CIT(A)'] for Assessment Year 2007-08. 2. The assessee raised Ground Nos.1 to 3 challenging the confirmation of reassessment made u/s 147 of the Act. With the consent of bot....

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....nion reopened the assessment and the assessment made thereon is not maintainable in law. The assessee challenged the validity of reassessment and the CIT(A) without examining the record confirmed the order of Assessing Officer regarding the validity of reopening of assessment. The ld. DR supported the order of Assessing Officer and CIT(A). 4. We find that the reasons recorded by the Assessing O....

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....he reasons recorded for initiation of proceedings u/s 147 of the Act. On perusal of the assessment order, it is noted that nowhere the Assessing Officer discussed about the objections raised by the assessee and without considering the same proceeded to reopen the assessment, is bad in law. Further we find that the assessee filed all the details such as audited accounts, tax audit report u/s 44AB a....