How many judgments cite A.L.A. Firm v. CIT?

128 judgments on BharatTax cite A.L.A. Firm v. CIT (189 ITR 285), spanning 2007 to 2026.

Which sections of the Income Tax Act does A.L.A. Firm v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 148, Section 147, Section 250, Section 151, Section 144.

A.L.A. Firm v. CIT

189 ITR 285Supreme Court of India1991#807 most cited

What is A.L.A. Firm v. CIT authority for?

Under the unamended Section 147(b), 'information' for reopening an assessment includes material already on record that comes to the Assessing Officer's notice subsequent to the original assessment, not just material extraneous to the record.

128

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2007 to 2026.

Also referred to as

A.L.A. Firm v. CIT · 189 ITR 285 · Section 147(b) · reopening of assessment · information for reassessment · material on record · subsequent notice · change of opinion · escapement of income · unamended Section 147

Also reported as

55 Taxmann 497

Sections most often in play

Section 143(3)Section 148 Section 147 Section 250 Section 151 Section 144 Section 69A Section 10(38)

Issues it is cited on

section 147(b)true and full disclosure full and true disclosure first proviso to section 147 kelvinator mere change of opinion live link change of opinion tangible material reopening of assessment escapement of income reason to believe

Judgments citing A.L.A. Firm v. CIT

Asst CIT 2(2)(1), Mumbai vs. State Bank of India, Mumbai

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3882/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) & SHRI JAGADISH (ACCOUNTANT MEMBER) I.T.A. No. 3680/Mum/2017 Assessment Year: 2010-11 State Bank of India Vs. The Assistant Commissioner of Financial Reporting & Taxation Income-tax, Circle-2(2)(1), Dept. Mumbai 3rd Floor, Corporate Centre Madam Cama Road Nariman Point Mumbai - 400021 [PAN: AAACS8577K] (Appellant) (Respondent) I.T.A. No. 3882/Mum/2017 Assessment Year: 2010-11 The Assistant Commissioner Vs. State Bank of India of Income-tax, Circle-2(2)(1), Financial Reporting & Taxation Mumbai Dept. 3rd Floor, Corpor…

State Bank of India, Mumbai vs. Asst CIT Cir 2(2), Mumbai

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 3680/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Apr 2026AY 2010-11

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 43B

Abhimanyu Nath, New Delhi vs. ITO Ward 30(1), Delhi

In the result, appeal of assessee in ITA No

ITA 4930/DEL/2025[2012-13]Status: DisposedITAT Delhi11 Feb 2026AY 2012-13

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Ms. Roli Choubey, CAFor Respondent: Shri Om Prakash, Sr. DR

Section 147Section 148

…hat the reopening was based on suspicion is unfounded, as the material on record clearly shows systemic entry operations, corroborated by the Investigation Wing's report. Courts, including in Kalyanji Mavji& Co. [1976] 102 I.T.R. 287(SC)and A.L.A. Firm,(1991) 189 ITR 285(SC) have upheld reassessments based on new external information suggesting suppression of facts. The appellate authority rightly held that the reopening was not only procedurally valid but also substantively justified, and the assessee failed to rebut the findings with credible evidence. Therefore, the conclusion in favor of the department merits…

Income Tax Officer, Ward-4(2), Jalandhar, Civil Lines vs. Sh. Barjesh Singhal, Modern Colony

In the result, the appeal filed by the revenue is allowed for statistical purpose

ITA 363/ASR/2024[2016-17]Status: DisposedITAT Amritsar13 Oct 2025AY 2016-17

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: None (Written submission)

Section 142(1)Section 143(3)Section 147Section 148Section 250

…-17 The Apex court has reopening in case of internal audit party when in this case, is third party information. And reopening is more valid. (3) (Moreover even otherwise reopening is fully justified as well settled law as under) (a) (AlA firm vs CIT (1991) 189 ITR 285 (SC) -The expression "information" in the context in which it occurs must in our judgment, mean instruction or knowledge derived from an external source bearing on the concerning facts or particulars of as or as to taw relating to a matter bean assessment Jurisdiction of the Income-tax Officer to reassess income arises if he has in consequence of…

Chandra Bros., Kolkata vs. I.T.O., Ward - 37(1), Kolkata

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1572/KOL/2024[2022-2023]Status: DisposedITAT Kolkata22 Jul 2025AY 2022-2023

Bench: Sri Pradip Kumar Choubey & Sri Rakesh Mishra

Section 143(1)Section 145(2)Section 250Section 44A

…different person). Accordingly, unless there is some income generating process, no income could be said to have originated from mere revaluation of assets. In this connection the following observation of the Hon'ble Apex Court in the case of ALA Firm Vs. CIT 189 ITR 285 is worth noticing and attention. "......it is possible to have a revaluation of the assets, for example, stock-in- trade before dissolution, any excess which arises on the revaluation is only an imaginary or notional profit and cannot be brought to tax for the following reasons: (i) As a result of such revaluation, there can be no profit, because…

Vinodbhai Laxmanbhai Pithiya, Vadodara vs. The Dy.CIT, Circle-1(1)(1) (Previously the ITO- Ward-1(2)(5)), Vadodara

In the result, this ground of appeal filed by the assessee is allowed for statistical purposes

ITA 919/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad18 Jun 2025AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Ms. Kinjal Shah, C.AFor Respondent: Shri Hargovind Singh, Sr. DR

Section 131Section 131(1)Section 133ASection 26A

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER & SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER I.T.A. No.919/Ahd/2024 (Assessment Year: 2016-17) Vinodbhai Laxmanbhai Pithiya Vs. Deputy Commissioner of (Indiviaual), Income Tax, Anil R. Shah (C.A.), Shreeji House, Circle-1(1)(1), 4th Floor, B/h. M.J. Library, Ellis Vadodara Bridge, Ahmedabad-380006 (Previously known as Income Tax Officer, Ward- 1(2)(5), Vadodara) [PAN No.AIAPP8126E] (Appellant) .. (Respondent) Appellant by : Ms. Kinjal Shah, C.A. Respondent by: Shri Hargovind Singh, Sr. DR 11.06.2025 Date of H…

Reeta Rana, Saharanpur vs. DCIT-3, Sahranpur

In the result, assessee’s appeal is allowed

ITA 4672/DEL/2024[2010-11]Status: DisposedITAT Delhi30 May 2025AY 2010-11

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Royassessment Year: 2010-11

Section 129Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148

…nd to further hold that it would be a case of ―no opinionǁ, would be to fly in the teeth of the two rulings. It is not even open to the revenue to urge such a proposition. 19. I must now refer to the judgment of the Supreme Court in A.L.A Firm Vs. CIT (1991) 189 ITR 285, wherein the provisions of section 147(b) of the Act as they stood before 01.04.1989 were being examined. That case was predominantly concerned with the question as to what would constitute ―informationǁ within the meaning of section 147(b). It was held that the statute does not require that the ITA 2026/2010 (FB) Page 44 of 48 information must b…

Rajeev Behl, New Delhi vs. ACIT, Central Circle-14, Delhi

Appeal is allowed

ITA 2030/DEL/2023[2013-14]Status: DisposedITAT Delhi30 May 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Royassessment Year: 2013-14

Section 143(1)Section 143(3)Section 147Section 148Section 151(1)Section 56

…nd to further hold that it would be a case of ―no opinionǁ, would be to fly in the teeth of the two rulings. It is not even open to the revenue to urge such a proposition. 19. I must now refer to the judgment of the Supreme Court in A.L.A Firm Vs. CIT (1991) 189 ITR 285, wherein the provisions of section 147(b) of the Act as they stood before 01.04.1989 were being examined. That case was predominantly concerned with the question as to what would constitute 7 ―informationǁ within the meaning of section 147(b). It was held that the statute does not require that the ITA 2026/2010 (FB) Page 44 of 48 information mus…

Akshay Kumar Rungta, Bangalore vs. Income Tax Officer, Ward 2(1), International Taxation

In the result, appeal filed by the assessee is allowed as per above terms

ITA 66/BANG/2024[2015-16]Status: DisposedITAT Bangalore07 May 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

For Appellant: Shri. Ravishankar S. V, AdvocateFor Respondent: Ms. Neha Sahay, JCIT(DR)(ITAT), Bangalore

Section 10(38)Section 143(3)Section 144CSection 147Section 147rSection 148Section 151Section 153Section 153CSection 250

…important and relevant is that the principle of "change of opinion" was equally applicable under the unamended provisions. The Supreme Court was, therefore, conscious of the said principle, when the observations mentioned above in A. L. A. Firm 55 Taxman 497/189 ITR 285 (SC) were made. 38. It will be appropriate to reproduce the succeeding passage from A. L. A. Firm 55 Taxman 497/189 ITR 285 (SC) (page 299): "We think there is force in the argument on behalf of the assessee that, in the face of all the details and statement placed before the Income-tax Officer at the time of the original assessment, it is diffic…

Ajay Bakliwal, Kota vs. ACIT, Central Circle, Kota

In the result, the appeal of the assessee is allowed

ITA 1275/JPR/2024[2012-13]Status: DisposedITAT Jaipur11 Apr 2025AY 2012-13

For Appellant: Sh. Rajendra Sisodia, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR

Section 129Section 132(1)Section 139Section 142Section 143(2)Section 143(3)Section 147Section 148Section 153ASection 2(22)(e)

…d by the AO and it was found correct. The issue was not examined earlier and new material come in knowledge. 2. 4. Audit Objection as Information Audit objections constitute "information" under Section 147(b) of the Act, as held in CIT v. A.L.A. Firm [(1991) 189 ITR 285 (SC)]. The AO can validly reopen an assessment based on such information if it reveals escapement of income. 2.5 Once objection is decided, the procedure laid down in landmark judgement of Apex Court in GKN Drive Shaft is applicable. There is no procedural lapse is mentioned by the appellant. 3. Addition Under Section 2(22)(e) (Ground Nos.2 & 3)…

Assistant Commissioner of Income Tax Circle-1, Bareilly vs. Wave Distilleries and Breweries Limited, Bareilly

Appeals of the Department stand dismissed

ITA 153/LKW/2023[2013-14]Status: DisposedITAT Lucknow28 Feb 2025AY 2013-14

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudhary

For Appellant: S/Shri Salil Kapoor, Vibhu Jain and Sumit Lalchandani, AdvocatesFor Respondent: Smt. Richa Rastogi, CIT (DR)

Section 115JSection 148

…ions of section 49(1) (b) of the 1.T. Act, 1961. Further in view of decision of Hon'ble Supreme Court in the case of Larsen & Toubro Ltd. Civil App No. 5390/2007., Hon'ble Supreme Court, ITO Vs. Sarabhai M Lakhani 243 ITR 1 and A.L.A. firm Vs. CIT reported in 189 ITR 285, proceedings u/s 147 may be initiated on the basis of decision of Hon'ble High Court of Karnataka in case of Principal Commissioner of Income Tax, ITA Nos.153 to 157/LKW/2023 C.O. Nos.23, 24, 21,22 and 25/LKW/2023 Page 8 of 61 Bangalore Vs. M/s Chamundi Winery & Distillery, [2018] 97 taxmann.com 568 (Karnataka)/ [2018] 408 ITR 402 (Karnataka) p…

Assistant Commissioner of Income Tax Circle 3 4 Mumbai, Mumbai vs. Glenmark Pharmaceuticals Limited, Mumbai

ITA 1374/MUM/2024[2015-16]Status: DisposedITAT Mumbai06 Sept 2024AY 2015-16

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Vijay MehtaFor Respondent: Shri P.D. Choughule

Section 143(3)Section 144BSection 144C(3)Section 147Section 148Section 37(1)Section 80G

…d by the decision of Hon'ble Delhi Tribunal in the case of Rural Electrification Corporation Ltd. Vs Addl. CIT, Rg. 15, New Delhi (2009) 34 SOT 159 Delhi. Also, the reliance is placed on the decision of Hon'ble Supreme Court in the case of A.L.A. Firm vs CIT (55 Taxmann 497) wherein it is held that information for re- opening the case can be obtained even from the record of original assessment from an investigation of material on record or the facts disclosed thereby or from the enquiry of research into facts or law. 13. Reliance is also placed on the decision of Hon'ble Delhi High Court in the case of Consolidat…

M/S Man Diesel & Turbo India Ltd., Maharashtra vs. DCIT, New Delhi

In the result, assessee’s appeal is hereby dismissed

ITA 4295/DEL/2015[2003-04]Status: DisposedITAT Delhi20 Aug 2024AY 2003-04

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singha.Y. 2003-04

Section 143(3)Section 147Section 148Section 250

…truly the necessary material facts. In the instant case since the assessee has failed to disclose fully and truly the necessary material facts, therefore, AO initiated proceedings u/s 147 by recording the proper reason. 5.1.9 In the case of ALA Firm vs. CIT 189 ITR 285 (SC), the Hon'ble Supreme Court has held that the assessing officer rightly initiated the proceedings for re-assessment after becoming aware of the relevant High Court decision even though it was available at the time of original assessment. The Hon'ble Court gave a view that the result of this decision is that the statute does not require that t…

Kotak Mahindra Bank Limited, Mumbai vs. Add/Joint/Deputy/ACIT, National E-Assessment Centre, Delhi

In the result, ground no. 1 raised by the revenue is

ITA 569/MUM/2023[2017-18]Status: DisposedITAT Mumbai08 Aug 2024AY 2017-18

Bench: Shri Amit Shuklaand

For Appellant: Shri Biswanath Das, Ld. DRFor Respondent: Shri Faroog Irani, Ld. AR

Section 250Section 36(1)Section 36(1)(vii)Section 36(2)(ii)Section 36(2)(viia)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER ITA No. 4056/Mum/2023 (AY.2012-13) ITA No. 4194/Mum/2023 (AY.2015-16) ITA No. 3676/Mum/2023 (AY.2016-17) ITA No. 4057/Mum/2023 (AY.2017-18) ITA No. 3677/Mum/2023 (AY.2018-19) ViPWNRr DCIT Circle — 2(3) (1), Room No. 552, 5" Floor, Aayakar Bhavan, M. K. Road, Church gate, Mumbai- 400 020. Vs. M/s. Kotak Mahindra Bank Ltd. 27, BKC, C-27, G-Block, Bandra East, Mumbai-400 051 PAN: AAACK4409J & 6. C.O. No. 38/Mum/2024(A.Y.2016-17) 7. ITA No. 569/Mum/2023 (AY.2017-18) 8…

DCIT-2(3)(1), Mumbai vs. Kotak Mahindra Bank Limited, Mumbai

In the result, ground no. 1 raised by the revenue is

ITA 4056/MUM/2023[2012-13]Status: DisposedITAT Mumbai08 Aug 2024AY 2012-13

Bench: Shri Amit Shuklaand

For Appellant: Shri Biswanath Das, Ld. DRFor Respondent: Shri Faroog Irani, Ld. AR

Section 250Section 36(1)Section 36(1)(vii)Section 36(2)(ii)Section 36(2)(viia)

ACIT, Central Circle - 3 (3), Chennai vs. M/S Land Marvel Homes, Chennai

In the result, appeal filed by the Revenue is allowed

ITA 1055/CHNY/2022[2012-2013]Status: DisposedITAT Chennai26 Jul 2024AY 2012-2013

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1055/Chny/2022 िनधा"रणवष" / Assessment Year: 2012-13 M/S. Land Marvel Homes, The Acit, V. 45-47, Old No. 22-23, Central Circle -3(3), 3Rd Floor, 1St Main Road, Chennai. Gandhi Nagar, Adyar, Chennai – 600 020. [Pan:Aabfl-4387-N] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. V. Nandakumar, Cit ""यथ"क"ओरसे/Respondent By : Shri. T. Banusekar, Advocate & Shri. Yeshwanth Kumar, Ca सुनवाई क" तारीख/Date Of Hearing : 06.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 26.07.2024 आदेश /O R D E R

For Appellant: Shri. V. Nandakumar, CITFor Respondent: Shri. T. Banusekar, Advocate &

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148

…what has been revalued is being “project advance” paid towards land shown under the head – Non current Asset portion in the Balance sheet. At this stage useful referene may be made to the ratio of the decision of the Hon’ble Supreme Court in A.L.A.Firm v CIT 189 ITR 285 (SC), which is applicable in the facts of the case. :-16-: ITA. No:1055/Chny/2022 16. At the outset, the asset in question is nothing but a “project advance” not held as current assets and in fact has been held as a “non current asset” which can be seen from pages 25 to 26 of the paper book filed by the assessee containing the balance sheet and…

Anil Bhutani, New Delhi vs. DCIT, Central Circle-1, Noida

In the result, the substantial question of law is answered in favour of the appellant and against the revenue

ITA 430/DEL/2020[2017-18]Status: DisposedITAT Delhi03 May 2024AY 2017-18

Bench: SHRI G. S. PANNU (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

Section 131Section 132(1)Section 132(4)Section 143(3)Section 69ASection 69C

…Section 144.” 10. In support of the above findings this Court had placed reliance on the following decisions of the Apex Court. (1) Chainruy Sampatram v. CIT 24 ITR 481. Anil Bhutani vs. DCIT (2) Investment Ltd. v. CIT. 77 ITR 533 and (3) A.L.A. Firm v. CIT 189 ITR 285. 11. We may recapitulate the following observations of the hon'be Supreme Court in Investigation Ltd. (supra): “A taxpayer is free to employ for the purpose of his trade, his own method of keeping accounts, and for that purpose to value his stock-in-trade either at cost or at market price. A method of accounting adopted by the trader consistently…

DCIT, Cir-3(3)(1), Mumbai vs. East West Pipeline Pvt Ltd., Mumbai

Accordingly, without any adjudication upon the merits, Ground No. 5 to 8 to raised by the Revenue are dismissed as being infructuous

ITA 1999/MUM/2023[2014-15]Status: DisposedITAT Mumbai05 Jan 2024AY 2014-15

Bench: SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Biswanath Das

Section 143(3)Section 144BSection 147Section 73(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL "E" BENCH, MUMBAI SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER Deputy Commissioner of Income Tax, Circle-3(3)(1), Mumbai, Room No. 609, Aaykar Bhavan, M.K. Road, Churchgate, Mumbai - 400020 …………… Appellant East West Pipeline Private Limited, 147, 14th Floor, Atlanta, 222, Vs Nariman Point, S.O. Mumbai - 400021 [PAN:AABCP4405E] ……………. Respondent Appearance For the Appellant/Department : Shri Biswanath Das For the Respondent/Assessee : Shri Madhur Agrawal Date Conclusion of hearing : 10.10.2023 Pronouncement of order : 05.01.2024 O R D E R Per Rah…

Jay Kishore Choubey, Rairangpur vs. ACIT, Circle-1, Asansol

In the result, appeal of the assessee stands allowed

ITA 2/CTK/2023[2010-11]Status: DisposedITAT Cuttack29 Nov 2023AY 2010-11

Bench: Before S/Shri George Mathan, Judicial & Girish Agrawalassessment Year : 2010-2011 2011 Jay Jay Kishore Kishore Choubey, Choubey, Vs. Acit, Circle Acit, Circle-1, Asansol. Rairangpur Bazar, Rairangpur, Rairangpur Bazar, Rairangpur, Mayurbhanj. Pan/Gir No. Pan/Gir No.Acmpc 1759 N (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.R.Mohanty P.R.Mohanty, Adv Revenue By : Shri Charan Das, Sr. Das, Sr. Dr Date Of Hearing : 29/11 11/2023 Date Of Pronouncement : 29/11 /11/2023 O R D E R Per Bench

For Appellant: Shri P.R.MohantyFor Respondent: Shri Charan Das, Sr

Section 147Section 148

…that satisfaction arrived at by any relevant material after following due procedure, It cannot be assailed. it may involve change of opinion but not at par with mere change of opinion. (Tilak raj bedi vs JCIT (2009) 319 ITR 385-P&H) 12 (AIA firm vs cit (1991) 189 ITR 285(sc) -The expression 'information' In the context in which it occurs must, in our judgment, mean instruction or knowledge derived from an external source P a g e 11 | 15 Assessment Year : 2010-2011 concerning facts or particulars, or as to law relating to a matter bearing on the assessment... Jurisdiction of the Income-tax Officer to reassess in…

Shri Bimal Paul, Silchar vs. Income Tax Officer, Ward-1, Silchar

In the result, both the appeals of the assessee are dismissed

ITA 8/GTY/2016[2011-12]Status: DisposedITAT Guwahati06 Oct 2023AY 2011-12

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2010-11 & Assessment Year: 2011-12

For Appellant: N o n eFor Respondent: Shri Arun Bhowmick, JCIT

Section 142Section 143(2)Section 143(3)Section 153(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL GAUHATI BENCH VIRTUAL HEARING AT KOLKATA BEFORE SHRI RAJPAL YADAV, VICE PRESIDENT AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER Assessment Year: 2010-11 & Assessment Year: 2011-12 Bimal Paul, Income Tax Officer, Ward-1, Prop. M/s. Lokenath Silchar, Assam Enterprise Rice Market, Vs. Fatak Bazar, Silchar- 788001, Assam (PAN: AJMPP9568K) (Appellant) (Respondent) Present for: Appellant by : N o n e Respondent by : Shri Arun Bhowmick, JCIT Date of Hearing : 17.07.2023 Date of Pronouncement : 06.10.2023 O R D E R PER GIRISH AGRAWAL, ACCOUNTANT MEMBER: Both the captioned appeals fi…