M/S. VINAYAK AGRO INDUSTRIES,ROURKELA vs. ITO WARD-4, ROURKELA
In the result, both appeals of the assessee are partly allowed for statistical purposes
ITA 107/CTK/2023[2009-10]Status: DisposedITAT Cuttack22 Nov 2023AY 2009-10
For Appellant: Shri N.K.Rout, AdvocateFor Respondent: Shri S.C.Mohanty, Sr. DR
Section 143(3)Section 148
penalty proceeding under Section 271 (1 )(c) of the Act.
1.11. The Assessment Order dated 30-12-2019 passed by Ld .ITO was carried the matter before Ld. CIT(Appeals) by the Appellant contending inter alia that:
(i) There is no material to form a reasonable belief. Entire proceeding initiated is based on borrowed satisfaction i.e. on the basis