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
6) of the Act, the assessment was completed and the
assessment could not have been set aside by the Commissioner by invoking
his powers under Section 263 of the Act. It is submitted that the learned
Commissioner had pre-decided the issue even at the stage of issuance of the
show cause notice under Section
