Vrinda Ispat Pvt. Ltd Vs ITO (ITAT Kolkata)
The assessee filed appeals against the orders of the National Faceless Appeal Centre for AYs 2013-14 to 2017-18. Appeals in ITA Nos. 6, 8 and 10/KOL/2025 were dismissed as withdrawn on the assessee’s request. In ITA No. 7/KOL/2025, the assessee challenged the reassessment proceedings initiated under Section 147 on the ground of limitation. The ITAT found that the notice issued under Section 148A(b) dated 30.06.2021, the notice under Section 148, and the assessment order dated 26.05.2023 were barred by limitation in view of the Supreme Court decision in PCIT v. Rajeev Bansal. The notice under Section 148 and the consequential assessment were quashed. In ITA No. 9/KOL/2025, the Tribunal held that for AY 2016-17, where reopening was initiated after three years, approval under Section 151 was required from the Principal Chief Commissioner of Income Tax. As the approval dated 14.07.2022 had been granted by the Principal Commissioner of Income Tax, it was held invalid. Consequently, the notice under Section 148 and the assessment order dated 25.05.2023 were also quashed. The remaining appeals were partly allowed by the ITAT Kolkata.
FULL TEXT OF THE ORDER OF ITAT KOLKATA
These are appeals preferred by the assessee against the orders of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 03.12.2024 & 22.11.2024 for the AYs2013-14 to 2017-18.
