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) ..

2) of the Income Tax Act but in section 263 of the Act nowhere about service of order has been mentioned. Therefore, this argument of the assessee with regard to ground No.1, is dismissed". m) In the case of CIT vs. Hi-Tech Arai Limited (321 ITR 477), the Hon'ble Madras High Court held that there is no merit

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) ..

2) of the Income Tax Act but in section 263 of the Act nowhere about service of order has been mentioned. Therefore, this argument of the assessee with regard to ground No.1, is dismissed". m) In the case of CIT vs. Hi-Tech Arai Limited (321 ITR 477), the Hon'ble Madras High Court held that there is no merit

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) ..

2) of the Income Tax Act but in section 263 of the Act nowhere about service of order has been mentioned. Therefore, this argument of the assessee with regard to ground No.1, is dismissed". m) In the case of CIT vs. Hi-Tech Arai Limited (321 ITR 477), the Hon'ble Madras High Court held that there is no merit

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) ..

2) of the Income Tax Act but in section 263 of the Act nowhere about service of order has been mentioned. Therefore, this argument of the assessee with regard to ground No.1, is dismissed". m) In the case of CIT vs. Hi-Tech Arai Limited (321 ITR 477), the Hon'ble Madras High Court held that there is no merit

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 rate prescribed in schedule II read with sub- section 2 of section 123 of the Companies Act, 2013. 3 4. Against this, the assessee preferred appeal before the ld. CIT(A), who dismissed the appeal of the assessee. Therefore, the present appeal is preferred by the assessee before us. Ground No.(i): 5. This ground is general

THE DHAMRA PORT COMPANY LIMITED,ODISHA vs. DCIT,CIRCLE 1(2), BHUBANESWAR, AAYAKAR BHAWAN, RAJASWA VIHAR, BHUBANESWAR, ORISSA

In the result, appeal of the assessee is allowed with the direction

section of 115J of the Act and the issue in hand in present appeal was not at all discussed/under dispute. In the other case of Milan Intermediates LLP, there was Nil amount of unabsorbed depreciation available, thus, the coordinate bench was of the view that least of the business loss or unabsorbed depreciation is to be considered. However, the facts

OMM SHREE REALCON PVT. LTD,BHUBANESWAR vs. PR.CIT-1, BHUBANESWAR

In the result, appeal of the assessee stands allowed

Bench: Before S/Shri George Mathan, Judicial & And Rajesh Kumarassessment Year : 2018-19 Om Shree Realcon Pvt Ltd., Om Shree Realcon Pvt Ltd., Vs. Pr. Cit- Bhubaneswar Bhubaneswar-1 Plot No.418, Forest Park, 8, Forest Park, Bhubaneswar. Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabco 3118 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri S.K.Sarangi, Ca S.K.Sarangi, Ca Revenue By : Shri M.K.Gautam, Pr. Cit (Osd) Pr. Cit (Osd) Date Of Hearing : 28 /0 06/2023 Date Of Pronouncement : 28 /0 /06/2023 O R D E R Per Bench

2,21,506/- Rabindra Sarani, Less: Tds- P a g e 7 | 31 Assessment Year : 2018-19 Kolkata 22,151/-) P a g e 8 | 31 Assessment Year : 2018-19 6. He further drew our attention to page 46 of the paper book, which was the further enquiry by the AO in the course of ‘e’ assessment, wherein, details

MODERN ENGLISH SCHOOL EDUCATION SOCIETY,KORAPUT vs. ITO (EXEMPTION WARD), BERHAMPUR

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

Bench: Before Shri George Mathan, Judicialassessment Year : 2015-16 Modern Modern English English School School Vs. Ito (Exemption Ward) Ito (Exemption Ward) Education Education Society, Society, Berhampur Berhampur Parabeda, Parabeda, Jeypore, Jeypore, Dist: Dist: Koraput Pan/Gir No. Pan/Gir No.Aacam 7223 Q (Appellant (Appellant) .. ( Respondent Respondent) Assessee By Assessee By : S/Shri P.K.Mishra, Adv/Kailash Panigrahi, Ca P.K.Mishra, Adv/Kailash Panigrahi, Ca Revenue By : Shri S.C.Mohanty, Sr Dr S.C.Mohanty, Sr Dr Date Of Hearing : 18 /0 04/2023 Date Of Pronouncement : 18 /0 /04/2023 O R D E R

15. In the instant case, it is not in dispute that the objects and activities of the trust or the year under consideration are same as were on 30.3.2015 when registration u/s.12AA was granted to the assessee by the CIT(Exemption) vide his order dated 26.3.2015. Further, as held by Ahmedabad Bench in the case of Shri Bhanushali Mitra Mandal

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

15,690/- which also included depreciation of Rs.40,35,943/-. In view of above facts, it was crystal clear that the assessee company had started commercial operations in F.Y. 2008-09 itself. The claim of the assessee that it had done only trial run and that the commercial production began after 31.03.2009, was found to be false. Accordingly

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

15,690/- which also included depreciation of Rs.40,35,943/-. In view of above facts, it was crystal clear that the assessee company had started commercial operations in F.Y. 2008-09 itself. The claim of the assessee that it had done only trial run and that the commercial production began after 31.03.2009, was found to be false. Accordingly

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

15,690/- which also included depreciation of Rs.40,35,943/-. In view of above facts, it was crystal clear that the assessee company had started commercial operations in F.Y. 2008-09 itself. The claim of the assessee that it had done only trial run and that the commercial production began after 31.03.2009, was found to be false. Accordingly

JAY KISHORE CHOUBEY,RAIRANGPUR vs. ACIT, CIRCLE-1, ASANSOL

In the result, appeal of the assessee stands allowed

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

2. Income from House Property under section 24(a) Rs. 1,48,031 3. Depreciation under section 32 Rs.1,89,824 The condition precedent to the exercise of the jurisdiction under section 147 is the formation of a reason to believe by the Assessing P a g e 3 | 15

B.C. BHUYAN CONSTRUCTION PVT. LTD.,BHUBANESWAR vs. DCIT, CORPORATE CIRCLE- 1(1), BHUBANESWAR

In the result, appeal of the assessee stands partly allowed for statistical purposes

Bench: Before S/Shri George Mathan, Judicial & Girish Agrawalwalassessment Year : 2014-15 B.C.Bhuyan Construction Pvt B.C.Bhuyan Construction Pvt Vs. Dcit, Corporate Circle Dcit, Corporate Circle - Ltd., Plot No.90, Palasuni, Ltd., Plot No.90, Palasuni, 1(1), Rasulgarh, Bhubaneswar Rasulgarh, Bhubaneswar Bhubaneswar Bhubaneswar Pan/Gir No. Pan/Gir No.Aadcb 3304 N (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri P.C.Sethi, Adv Revenue By Revenue By : Shri Saroj Kumar Mahapatra, Saroj Kumar Mahapatra, Pr. Cit Dr Date Of Hearing : 20/07 7/2023 Date Of Pronouncement : 20/0 /07/2023

15 Assessment Year : 2014-15 “ 7. A Division Bench decision of this Court in First Leasing Co. of India Ltd. v. CIT (No. 2) [2000] 244 ITR 238 was brought to our notice, in which question arose as to whether individual bottles can be regarded as plant for the purpose of the first proviso to section

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)

15. However, our view finds support from the decision of the Hon‟ble Jurisdictional High Court of Orissa in the case of Orissa State Police Housing & Welfare Corporation Ltd., reported in [2022] 139 taxmann.com 207 (Orissa), wherein the Hon‟ble High Court in para 14 has held as under :- 14. Section 263 of the Act requires the CIT, after hearing

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

15. However, our view finds support from the decision of the Hon‟ble Jurisdictional High Court of Orissa in the case of Orissa State Police Housing & Welfare Corporation Ltd., reported in [2022] 139 taxmann.com 207 (Orissa), wherein the Hon‟ble High Court in para 14 has held as under :- 14. Section 263 of the Act requires the CIT, after hearing

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

15. However, our view finds support from the decision of the Hon‟ble Jurisdictional High Court of Orissa in the case of Orissa State Police Housing & Welfare Corporation Ltd., reported in [2022] 139 taxmann.com 207 (Orissa), wherein the Hon‟ble High Court in para 14 has held as under :- 14. Section 263 of the Act requires the CIT, after hearing

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)

15. However, our view finds support from the decision of the Hon‟ble Jurisdictional High Court of Orissa in the case of Orissa State Police Housing & Welfare Corporation Ltd., reported in [2022] 139 taxmann.com 207 (Orissa), wherein the Hon‟ble High Court in para 14 has held as under :- 14. Section 263 of the Act requires the CIT, after hearing

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)

15. However, our view finds support from the decision of the Hon‟ble Jurisdictional High Court of Orissa in the case of Orissa State Police Housing & Welfare Corporation Ltd., reported in [2022] 139 taxmann.com 207 (Orissa), wherein the Hon‟ble High Court in para 14 has held as under :- 14. Section 263 of the Act requires the CIT, after hearing