PRINCIPAL COMMISSIONER OF INCOME TAX, SILIGURI vs. SRI SATYA NARAYAN SARIA
In the result, these appeals are allowed and the substantial
ITAT/168/2021HC Calcutta14 Jun 2022
Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA
term was
explained by the Hon’ble Supreme Court in Bhikhubhai Vihlabhai Patel
Versus State of Gujarat 71 which was relied on in the case of Hotel Regal
International & Anr. Versus ITO & Another, WP No. 22950 (W) of 2009
in the High Court at Calcutta. To explain the meaning of the term “opinion”,
reference was made to P. Ramanatha Aiyar