9911796707
TMI Blog2023 (2) TMI 1359X X X X Extracts X X X X X X X X Extracts X X X X ..... dmittedly, the appellant did not seek for reasons for re-opening nor filed any objection to the re-opening but submitted that the original return of income filed on 30th October, 2001 may be treated as return of income pursuant to the notice issued u/s 148. AO proceeded with the assessment by resorting to the scrutiny procedure. From the order passed by the AO, we find that detailed factual aspect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the Income Tax Act, 1961 (the Act for brevity) is directed against the order dated 15th May, 2009 passed by the Income Tax Appellate Tribunal, C Bench, Kolkata (the Tribunal) in ITA No.1655/Kol/2007 for the assessment year 2001-02. The appeal was admitted on 3rd March, 2010 on the following substantial questions of law: (i) Whether on the facts and in the circumstances of the case, the Income-ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assisted by Mr. Avra Mazumdar, Mr. Suman Bhowmick and Mr. Samrat Das, learned Advocates for the appellant and Mr. Amit Sharma, learned standing counsel for the respondent/department. Learned Advocate appearing for the appellant submitted that the appellant is not pressing substantial question of law No.1. The said submission is placed on record and substantial question of law No.1 is rejected as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ness of the order and granted partial relief to the assessee by reducing the percentage of undisclosed purchases/sales. The assessee carried the matter on appeal to the learned Tribunal which further reduced the addition to 10% towards purchase on the undisclosed sales. In our considered view, the entire matter is factual and there is no error in the decision making process adopted by the learned ..... X X X X Extracts X X X X X X X X Extracts X X X X
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