ITAT Kolkata Quashed Reassessment for Borrowed Satisfaction in Share Capital Case

Sumangal Jewels Private Limited Vs DCIT (ITAT Kolkata) The appeal before the Income Tax Appellate Tribunal arose from an order passed by the Commissioner of Income Tax (Appeals), Kolkata, confirming a reassessment made under Sections 147/143(3) of the Income-tax Act, 1961. The assessee challenged the very assumption of jurisdiction for reopening the assessment, contending that the mandatory conditions for invoking Section 147 were not satisfied and that the notice issued under Section 148 was void ab initio. The facts showed that a search and survey operation was conducted on the Bhalotia Grou...