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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 August 27, 2024 passed by
the Income Tax Appellate Tribunal, “C” Bench, Kolkata (the Tribunal) in
ITA/155/Kol/2023 for the assessment year 2008-09.
The revenue has raised the following substantial questions of law for
consideration :
“1. Whether in the facts and circumstances of the case the Learned
Tribunal has substantially erred in law in quashing the reopening
proceeding under Section 147 of the Income Tax Act, 1961 on the ground
that the reopening was based on borrowed satisfaction and lacked
application of mind by the Assessing Officer ?
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