2025 (5) TMI 1093

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..... Bhattacharjee, Adv. For the Respondent : Mr. Avra Mazumder, Adv., Mr. Girdhar Dhelia, Adv., Mr. Suman Bhowmik, Adv., Mr. Samrat Das, Adv., Ms. Elina Dey, Adv. and Mr. Sourendra Nath Banerjee, Adv. ... ORDER: 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 30.1.2024 passed by the Income Tax Appellate Trib .....

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..... nature and source is not explained? c. Whether the learned Tribunal has committed substantial error in law in holding that the assessee has proved the identity and genuineness of transaction, ignoring the decision of the Hon'ble Supreme Court in the case of Novodaya Cstle [P] Ltd. [2015] 59 Taxmann.com 18[SC] wherein the Apex court held that certificate of incorporation, PAN etc were not suffici .....

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..... ciples laid down in the matter of Pr. CIT 5, Kolkata Vs Swati Bajaj reported in 2022 SCC Online 1572 [Cal] ?" The learned Tribunal had allowed the assessee's appeal on the ground that the source of verification provision was inserted under section 68 on and from Finance Act, 2012 with effect from 1.4.2013 and it cannot have retrospective effect for the assessment year 2011-12, the year under cons .....

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