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The assessee is a company and it filed its return of income declaring total income of Rs. 3,10,460/- on 29/09/2009. The return was processed u/s 143(1) of the Act. The assessment was reopened u/s 147 of the Act by issual of notice u/s 148 of the Act dt. 30/03/2017. In compliance, the assessee filed return of income on 11/04/2016, declaring the very same income as originally declared. The Assessing Officer issued notice u/s 143(2) and 143(1) of the Act and thereafter completed assessment u/s 143(3) r.w.s. 147 of the Act was completed on 13/12/2016, determining the total income at Rs. 18,42,160/- interalia making an addition of Rs. 15,31,700/-, as cash credit being, net income earned from Client Code Modification (CCM). Aggrieved the assessee carried the matter in appeal before the ld. First Appellate Authority. The ld. CIT(A) rejected the arguments of the assessee, both against the reopening of the assessment as well as against the merits of the addition.Further aggrieved the assessee is in appeal before Tribunalchallenging both the reopening of the assessment as well as the addition made u/s 68 of the Act on merits.

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Sec. 147 of Income Tax Act, 1961— Reassessment —AEREO DEALCOMM PVT. LTD. vs. ITO.[2020] 25 ITCD Online 083 (ITAT-KOLKATA)