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The Court : This appeal filed by the revenue under Section 260A of the Income
Tax Act, 1961 (the Act) is directed against the order dated May 3, 2024 passed by the
Income Tax Appellate Tribunal, B – Bench, Kolkata (the Tribunal) in ITA/639/Kol/2022
for the assessment year 2015-16.
The revenue has raised the following substantial questions of law for
consideration :
“i) Whether on the facts and in the circumstances of the case, the Learned Tribunal has
committed substantial error in law in quashing the reassessment proceedings under
Section 147 of the Income Tax Act, 1961 on the premise that the notices under Section
148 and Section 143(2) of the Income Tax Act, 1961 were not issued by the transferee
Assessing Officer post transfer?
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