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TMI Blog2022 (11) TMI 1324X X X X Extracts X X X X X X X X Extracts X X X X ..... ing Officer has issued summons under Section 131 of the Act to the directors of the Shareholding Company M/s. Laxmi Timber Pvt. Ltd. in consonance with the direction issued by the Principal Commissioner of Income Tax under Section 263 of the Act. This finding would be seen from paragraphs 5 to 7 of the assessment order. Thus the learned Tribunal on re-verification of the facts found that this is n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ected against the order dated 17.02.2021 passed by the Income Tax Appellate Tribunal, A Bench, Kolkata (Tribunal) in ITA No. 303/Kol/2020 for the assessment year 2013-2014. The revenue has raised the following substantial questions of law for consideration : i) Whether the Learned Tribunal has committed substantial error in law by not upholding the order passed under section 263 of the Income ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Act of PCIT dated 21.02.2020 whereas Apex Court in the case of Pr. CIT Vs NRA Iron Steel Pvt. Ltd. held that the practice of conversion of unaccounted money through the cloak of share capital and premium must be subjected to careful scrutiny ? We have heard Mr. Samarjit Roychowdhury, learned standing Counsel along with Mr. Soumen Bhattacharjee for the appellant and Mr. S.M. Surana, lear ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Section 263 of the Act. This finding would be seen from paragraphs 5 to 7 of the assessment order. Thus the learned Tribunal on re-verification of the facts found that this is not a case of non application of mind nor this is a case of failure to re-appreciate the facts and concluded that the view taken by the assessing officer was a plausible view. That apart we note that the assessing officer co ..... X X X X Extracts X X X X X X X X Extracts X X X X
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