PRINCIPAL COMMISSIONER OF INCOME TAX-9, KOLKATA vs. GOPAL PRASAD TIKMANI
In the result, these appeals are allowed and the substantial
ITAT/151/2021HC Calcutta14 Jun 2022
Bench: HON'BLE JUSTICE T. S. SIVAGNANAM,HON'BLE JUSTICE HIRANMAY BHATTACHARYYA
56 266 (ELT) 422 (SC)
ITAT NO. 06 OF 2022 AND ETC. BATCH
Page 60 of 150
reliance was placed on the decision in Sesa Sterlite Limited Versus
Assistant Commissioner of Income Tax and Others 57 for the proposition
on whom the onus of proof would lie, reliance was placed on the decision of
the Learned tribunal in PCIT, Kolkata
