HC quashes Reassessment notice & Proceeding based on wrong premises

Realization Stock & Equity Pvt. Ltd. Vs. ITO (Calcutta High Court) One of the reasons for reopening of assessment is that no regular assessment under Section 143 (3) of the Act was made in the instant case and even in the last paragraph of the said reason again it has been recorded again that no assessment order as per Section 2 (40) of the Act was made in the instant case which is totally incorrect and contrary to the respondent’s own record from where it appears that the regular assessment under Section 143 (3) of the Act was passed on 10th December, 2019 being Annexure P-10 to the wri...