MR. MANOJ KUMAR NAYAK,BHUBANESWAR vs. DDIT, INTERNATIONAL TAXATION, BHUBANESWAR, BHUBANESWAR

In the result, the appeal of the assessee is allowed for statistical purposes

139(5) of the I.T. Act and the CIT is also justified in confirming the view of the learned Assessing Officer.‖ 14. On perusal of the above decision of the Hon’ble jurisdictional High Court, it is clear that the assessment in the above case was completed u/s.143(3) of the Act on the basis of original return filed u/s.139

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT, CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

139, 147, 148, 149, 151 and 153 of the Act". v.) The Hon'ble Allahabad High Court in the case of Savesh Kumar Agarwal vs. Union of India (35 taxmann.com 85) held in para-22 & 23 that the question which now called for consideration was whether on receipt of satisfaction note, even if the assessing authority receiving satisfaction note

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

139, 147, 148, 149, 151 and 153 of the Act". v.) The Hon'ble Allahabad High Court in the case of Savesh Kumar Agarwal vs. Union of India (35 taxmann.com 85) held in para-22 & 23 that the question which now called for consideration was whether on receipt of satisfaction note, even if the assessing authority receiving satisfaction note

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT, CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

139, 147, 148, 149, 151 and 153 of the Act". v.) The Hon'ble Allahabad High Court in the case of Savesh Kumar Agarwal vs. Union of India (35 taxmann.com 85) held in para-22 & 23 that the question which now called for consideration was whether on receipt of satisfaction note, even if the assessing authority receiving satisfaction note

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT ,CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

139, 147, 148, 149, 151 and 153 of the Act". v.) The Hon'ble Allahabad High Court in the case of Savesh Kumar Agarwal vs. Union of India (35 taxmann.com 85) held in para-22 & 23 that the question which now called for consideration was whether on receipt of satisfaction note, even if the assessing authority receiving satisfaction note

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT, CORPORATE CIRCLE 1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

139, 147, 148, 149, 151 and 153 of the Act". v.) The Hon'ble Allahabad High Court in the case of Savesh Kumar Agarwal vs. Union of India (35 taxmann.com 85) held in para-22 & 23 that the question which now called for consideration was whether on receipt of satisfaction note, even if the assessing authority receiving satisfaction note

BIBHUDUTTA PANDA,BHUBANESWAR vs. ASST.CIT, CORPORATE CIRCLE-1(2), BHUBANESWAR

In the result, all appeals of the assessee stand allowed

Bench: Shri George Mathan & Shri Arun Khodpiaआयकर अऩीऱ सं/Ita Nos.76 To 81/Ctk/2022 (ननधाारण वषा / Assessment Years :2007-2008 To 2012-2013) Bibhudutta Panda, Vs Acit, Corporate Circle-1(2), Plot No.73 & 74, Jayadev Vihar, Bhubaneswar Bhubaneswar-751013 Pan No. :Adapp 6398 R (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

139, 147, 148, 149, 151 and 153 of the Act". v.) The Hon'ble Allahabad High Court in the case of Savesh Kumar Agarwal vs. Union of India (35 taxmann.com 85) held in para-22 & 23 that the question which now called for consideration was whether on receipt of satisfaction note, even if the assessing authority receiving satisfaction note

MAHANADI COALFIELDS LTD.,SAMBALPUR vs. DCIT, CIRCLE-2(1), SAMBALPUR

In the result, appeal of the assessee is partly allowed for

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.174/Ctk/2018 (नििाारण वषा / Assessment Year : 2015 - 2016) Mahanadi Coalfields Ltd., Vs. Dcit, Circle-2(1), Sambalpur Jagriti Vihar, Burla, Sambalpur स्थायी ऱेखा सं./Pan No. : Aabcm 5188 P (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By : Shri S.S.Podar, Ca राजस्व की ओर से /Revenue By : Shri S.M.Keshkamat, Citdr सुनवाई की तारीख / Date Of Hearing : 15/01/2020 घोषणा की तारीख/Date Of Pronouncement : 05/06/2020 आदेश / O R D E R Per L.P.Sahu, Am :

Section 32(1)(ii). The commercial rights of exploration and licenses acquired by the assessee being in the nature of intangible assets are eligible for the claim of depreciation at the rate prescribed u/s 32(1)(ii) of the Act. The AO himself in his order had observed that as a result of entering into such an agreement

DEOKARAN DAS RAMBILASH,SUNDARGARH vs. ITA, WARD-04, , ROURKELA

In the result, appeal of the assessee is partly allowed

Bench: Shri Shri Chandra Mohan Garg, Judicialassessment Year : 2010-2011 Deokaran Das Deokaran Das Rambilash, Old Vs. Ito, Ward -4, Station Road, Rourkela. Station Road, Rourkela. Rourkela. Pan/Gir No.Aadfd 9708 K Aadfd 9708 K (Appellant) (Appellant .. ( Respondent Respondent) Assessee By : Shri S.K.Agarwalla, Ar Ar Revenue By : Shri S.C.Mohanty, Dr Dr Date Of Hearing : 28/05/ 2021 1 Date Of Pronouncement : 14/06/20 /2021 O R D E R

depreciation which are to be allowed as per the provisions of the Act.” P a g e 1 | 9 Assessment Year : 2010-2011 3. The appeal is time barred by 359 days. The assessee has filed condonation petition supported by an affidavit sworn by Sri Suresh Chandra Agarwal, Managing Partner of M/s. Deokaran Das Rambilash, wherein, it is stated that

MGM GREEN ENERGY LIMITED,BHUBANESWAR vs. DCIT,CIRCLE-1(1), BHUBANESWAR

In the result, appeal of the assessee is partly allowed

Bench: Shri George Mathan & Shri Manish Agarwalआयकर अऩीऱ सं/Ita No.370/Ctk/2019 (ननधाारण वषा / Assessment Year : 2014-2015) Mgm Green Energy Limited, Vs Jcit, Range Rourkela, Rourkela 5-A, Forest Park, Bhubaneswar Pan No. :Aahcm 8472 C (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Sh A.K.Sabat & Sh B.K.Mahapatra, Cas राजस्व की ओर से /Revenue By : Shri Sanjay Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 22/05/2024 घोषणा की तारीख/Date Of Pronouncement : 22/05/2024 आदेश / O R D E R Per Bench : This Appeal Is Filed By The Assessee Against The Order Of The Ld. Cit(A)-1. Bhubaneswar, Dated 11.06.2019, In I.T.Appeal No.0388/16-17 For The Assessment Year 2014-2015. 2. The Assessee Has Taken As Many As Six Grounds Of Appeal, Relating To Various Additions/Disallowances Made To The Income Declared By The Assessee & Also Against The Adjustments Made In The Book Profit U/S.115Jb Of The Act. The Grounds Raised By The Assessee Are As Under :- I) The Ld. Cit(A) Is Erred In Dismissing The Appeal Of The Assessee, Which Is Arbitrary, Erroneous & Bad, Both In The Eyes Of Law. Ii) Disallowance Of Interest Expenses U/S.36(Iii) Of The Act At Rs.1,65,18,400/-; Iii) Disallowance Of Expenses U/S.14A Of The Act/Rule 8D Of It Rules At Rs.2,44,82,488/-; Iv) Addition Of Disallowance Of Expenses U/S.14A At Rs.2,44,82,488/- In The Book Profit As Computed U/S 115Jb; V) Addition/Disallowance Of Expenses U/S.115Jb Of The Act Under The Book Profits; Vi) Disallowance Of Differential Depreciation Of Rs.1,16,63,697/-

depreciation reserves and, thus, entire investment had been made in sister concern out of interest-free funds - Commissioner (Appeals) accepted assessee's contention and directed Assessing Officer to allow entire amount of interest under section 36(1)(iii) - Tribunal upheld order of Commissioner (Appeals) - On instant appeal, it was seen that Commissioner (Appeals) as 10 also Tribunal had recorded

M/S. PRAGATI MILK PRODUCT PVT. LTD.,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

In the result, all the three appeals of the assessee for respective assessment years under consideration are allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita Nos.143 To 145/Ctk/2022 (ननधाारण वषा / Assessment Year : 2012-2013 To 2014-2015) M/S Pragati Milk Products(P) Ltd. Vs Acit, Central Circle, Cuttack Plot No.71/A/1, New Industrial Estate, Jagatpur, Cuttack-754021 Pan No. :Aaecp 6353 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.R.Mohanty, Advocate राजस्व की ओर से /Revenue By : Shri Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 11/10/2023 घोषणा की तारीख/Date Of Pronouncement : 11/10/2023 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Bhubaneswar, Dated 12.10.2018, Passed In I.T.Appeal No.0487/2017-18 For The Assessment Year 2012-2013. 2. It Was Submitted By The Ld. Ar That The Facts In All The Cases Are Identical. It Was The Submission That There Was Search In The Premises Of The Assessee. As A Consequence Of Search, Assessment Came To Be Completed U/S.153A Of The Act. In The Assessment U/S.153A Of The Act, The Assessee Had Been Granted The Benefit Of Deduction U/S.80Ib(11A) Of The Act. It Was The Submission That The Said Assessment Order Was The Subject Matter Of Rectification Application On Multiple Occasions & In The Third Round Of Rectification Application The Ao Has Withdrawn The Benefit Of Deduction U/S.80Ib (11A) Of The Act. It Was The Submission That The 2

depreciable asset. This was permitted on the mistaken application of law. Later on by invoking the provisions of section 154 ITO withdrew the permission given to the assessee to exercise its open to offer fair market value as on 1-1-1954. Since there is an error apparent on the face of the record in passing the original assessment order

M/S. PRAGATI MILK PRODUCT PVT. LTD.,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

In the result, all the three appeals of the assessee for respective assessment years under consideration are allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita Nos.143 To 145/Ctk/2022 (ननधाारण वषा / Assessment Year : 2012-2013 To 2014-2015) M/S Pragati Milk Products(P) Ltd. Vs Acit, Central Circle, Cuttack Plot No.71/A/1, New Industrial Estate, Jagatpur, Cuttack-754021 Pan No. :Aaecp 6353 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.R.Mohanty, Advocate राजस्व की ओर से /Revenue By : Shri Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 11/10/2023 घोषणा की तारीख/Date Of Pronouncement : 11/10/2023 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Bhubaneswar, Dated 12.10.2018, Passed In I.T.Appeal No.0487/2017-18 For The Assessment Year 2012-2013. 2. It Was Submitted By The Ld. Ar That The Facts In All The Cases Are Identical. It Was The Submission That There Was Search In The Premises Of The Assessee. As A Consequence Of Search, Assessment Came To Be Completed U/S.153A Of The Act. In The Assessment U/S.153A Of The Act, The Assessee Had Been Granted The Benefit Of Deduction U/S.80Ib(11A) Of The Act. It Was The Submission That The Said Assessment Order Was The Subject Matter Of Rectification Application On Multiple Occasions & In The Third Round Of Rectification Application The Ao Has Withdrawn The Benefit Of Deduction U/S.80Ib (11A) Of The Act. It Was The Submission That The 2

depreciable asset. This was permitted on the mistaken application of law. Later on by invoking the provisions of section 154 ITO withdrew the permission given to the assessee to exercise its open to offer fair market value as on 1-1-1954. Since there is an error apparent on the face of the record in passing the original assessment order

M/S. PRAGATI MILK PRODUCT PVT. LTD.,CUTTACK vs. ACIT, CENTRAL CIRCLE, CUTTACK

In the result, all the three appeals of the assessee for respective assessment years under consideration are allowed

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita Nos.143 To 145/Ctk/2022 (ननधाारण वषा / Assessment Year : 2012-2013 To 2014-2015) M/S Pragati Milk Products(P) Ltd. Vs Acit, Central Circle, Cuttack Plot No.71/A/1, New Industrial Estate, Jagatpur, Cuttack-754021 Pan No. :Aaecp 6353 J (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. ननधााररती की ओर से /Assessee By : Shri P.R.Mohanty, Advocate राजस्व की ओर से /Revenue By : Shri Dr. Abani Kanta Nayak, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 11/10/2023 घोषणा की तारीख/Date Of Pronouncement : 11/10/2023 आदेश / O R D E R Per Bench : These Are The Appeals Filed By The Assessee Against The Order Of The Ld. Cit(A)-2, Bhubaneswar, Dated 12.10.2018, Passed In I.T.Appeal No.0487/2017-18 For The Assessment Year 2012-2013. 2. It Was Submitted By The Ld. Ar That The Facts In All The Cases Are Identical. It Was The Submission That There Was Search In The Premises Of The Assessee. As A Consequence Of Search, Assessment Came To Be Completed U/S.153A Of The Act. In The Assessment U/S.153A Of The Act, The Assessee Had Been Granted The Benefit Of Deduction U/S.80Ib(11A) Of The Act. It Was The Submission That The Said Assessment Order Was The Subject Matter Of Rectification Application On Multiple Occasions & In The Third Round Of Rectification Application The Ao Has Withdrawn The Benefit Of Deduction U/S.80Ib (11A) Of The Act. It Was The Submission That The 2

depreciable asset. This was permitted on the mistaken application of law. Later on by invoking the provisions of section 154 ITO withdrew the permission given to the assessee to exercise its open to offer fair market value as on 1-1-1954. Since there is an error apparent on the face of the record in passing the original assessment order

RAJESWAR THAKUR,BHAWANIPATNA vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE -1(1), SAMBALPUR

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.143 & 144/Ctk/2025 (निर्धारण वर्ष / Assessment Years : 2012-2013 & 2014-2015) Rajeswar Thakur Pardeshpada, Near Balaji Temple Bhawanipatna, Kalahandi-766001 Vs Acit, Circle-1(1), Sambalpur Pan No. :Aaspt 7155 M (अपीलार्थी / Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Assessee By : Shri S.K.Agrawalla, Ca राजस्व की ओर से /Revenue By : Shri Nishant Rao B, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 21/07/2025 घोषणा की तारीख/Date Of Pronouncement : 21/07/2025 आदेश / Order Per Bench : These Two Appeals Filed By The Assessee Against The Order Of The Id. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Both Dated 27.12.2024 For Assessment Years 2012-2013 & 2014-2015.

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year) : Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall

ACIT, SAMBALPUR vs. M/S MAHANADI COALFIELDS LTD, SAMBALPUR

In the result, appeals filed by the revenue for the assessment years

Bench: S/Shri N.S Saini & Pavan Kumar Gadale

depreciation on the ground that the assessee is not engaged in the business of manufacturing or production of any article or thing. On appeal, the CIT(A) deleted the addition made by the Assessing Officer by following the various judicial decisions including the Hon’ble Supreme Court in the case of CIT s. Sesa

M/S. GRID CORPORATION OF ORISSA LIMITED,BHUBANESWAR vs. ACIT-(TDS), BHUBANESWAR

In the result, appeal of the assessee stands allowed

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2009-2010 2010 Grid Corporation Of Orissa Grid Corporation Of Orissa Vs. Acit (Tds), Acit (Tds), Ltd., Ltd., Gridco Gridco House, House, Bhubaneswar. Bhubaneswar. Janapath, Bhubaneswar. Janapath, Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabcg 5398 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : S/Shri Ved Jain/P.Venugopal Rao /P.Venugopal Rao, Ars Revenue By : Shri M.K.Gautam, M.K.Gautam, Cit Dr Date Of Hearing : 20/0 02/2023 Date Of Pronouncement : 20/0 /02/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A)-1, Bhubaneswar, 1, Bhubaneswar, Dated 12.7.2019 In Appeal No. In Appeal No.0035/17-18 For The Assessment Year The Assessment Year 2009-2010. 2. S/Shri Ved Jain & P.Venugopal Rao, S/Shri Ved Jain & P.Venugopal Rao, Ld Ar Ld Ars Appeared For The Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue. Assessee & Shri M.K.Gautam, Ld Cit Dr Appeared For The Revenue.

depreciation was allowed overlooking section 8OVVA of the Act. Overlooking of a statutory provision is clearly a mistake apparent on record and on that basis, rectification under section 154 of the Act was clearly admissible. Impermissibility of deduction is not debatable if section 80VVA is applied. This being so, the CIT(A) as well as the Tribunal erred

ORISSA AIR PRODUCTS PVT. LTD.,DHENKANAL vs. ACIT, CIRCLE-1(2), BHUBANESWAR

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri N.S Sainiassessment Year : 2012-2013

139 (1) but not to labour welfare funds. The second proviso was then inserted to allow deduction of contribution to, inter alia, any provident fund if made before the due date as per the Employees Provident Fund Act during the previous year. This again resulted in implementation problems as a result of which the second proviso was deleted

M/S GRID CORPORATION OF ORISSA LTD.,BHUBANESWAR vs. DCIT, CIRCLE-1(1), BHUBANESWAR

In the result, both the appeals of the assessee stand allowed

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita Nos.34 & 35/Ctk/2019 2019 Assessment Assessment Years : 2013-14 & 2014 14 & 2014-15 M/S. Grid Corporation Of M/S. Grid Corporation Of Vs. Dcit, Circle Dcit, Circle -1(1), Orissa Ltd., Gridco House, Orissa Ltd., Gridco House, Bhubaneswar. Bhubaneswar. Janpath, Bhubaneswar Janpath, Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabcg 5398 P (Appellant (Appellant) .. ( Respondent Respondent)

139 taxmann.com 207 )Orissa), wherein, in para 14, it has been held as follows: “Section 263 of the Act requires the CIT, after hearing the assessee, to pass an order by making “such enquiry as he deems necessary”. The purpose of such an enquiry would be to arrive at a subjective view that the order of the AO was erroneous

M/S. GRID CORPORATION OF ORISSA LIMITED,BHUBANESWAR vs. DCIT, CIRCLE-1(1), BHUBANSWAR

In the result, both the appeals of the assessee stand allowed

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita Nos.34 & 35/Ctk/2019 2019 Assessment Assessment Years : 2013-14 & 2014 14 & 2014-15 M/S. Grid Corporation Of M/S. Grid Corporation Of Vs. Dcit, Circle Dcit, Circle -1(1), Orissa Ltd., Gridco House, Orissa Ltd., Gridco House, Bhubaneswar. Bhubaneswar. Janpath, Bhubaneswar Janpath, Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabcg 5398 P (Appellant (Appellant) .. ( Respondent Respondent)

139 taxmann.com 207 )Orissa), wherein, in para 14, it has been held as follows: “Section 263 of the Act requires the CIT, after hearing the assessee, to pass an order by making “such enquiry as he deems necessary”. The purpose of such an enquiry would be to arrive at a subjective view that the order of the AO was erroneous