2017 (11) TMI 2005

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...., Addl. CIT, DR ORDER This is an appeal filed by the assessee against the order of Ld. CIT(A)-XX, Kolkata dated 09.09.2014 for AY 2008-09. 2. At the outset, Ld. Counsel for the assessee drew our attention to the additional ground of appeal wherein the assessee has raised the ground that the assessee had objected to the reopening proposed by the AO u/s. 147/148 of the Income-tax Act, 1961 (herei....

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.... of objection to the reasons recorded u/s. 148(2) for the Asst. Year 2008-09". In the first para itself the assessee has placed on record their objection to the reassessment proceeding initiated by the AO u/s. 147 of the Act. We note that the objection against reopening runs to six pages and in the last para, the Ld. AR prays to the AO to deal with the objection raised before proceeding in the mat....

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....off the objection raised by the assessee vide letter dated 23.04.2013. On the other hand, we note that the AO notes thereafter that he has passed the assessment order u/s. 147/143(3) of the Act. From the aforesaid facts we note that the assessee's objection after going through the reasons recorded for reopening, was not done at all by the AO before passing the reassessment order which is per se ag....