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

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

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