DEPUTY COMMISSIONER OF INCOME TAX, CENTAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

In the result, all the four appeals of the Revenue are dismissed

reassessment in accordance with the law\nstated in these cases. Learned Counsel also relies on the case of Asstt.\nCIT v. Dhariya Construction Co. [2011] 197 taxmann.com\n202/[2010] 328 ITR 515 (SC) to assail reliance by the Revenue on\nthe opinion of Shah Commission so far as the alleged case of under-\ninvoicing is concerned. In that case

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, SAMBALPUR vs. SMT. INDRANI PATNAIK, ROURKELA

In the result, all the four appeals of the Revenue are dismissed

reassessment in accordance with the law\nstated in these cases. Learned Counsel also relies on the case of Asstt.\nCIT v. Dhariya Construction Co. [2011] 197 taxmann.com\n202/[2010] 328 ITR 515 (SC) to assail reliance by the Revenue on\nthe opinion of Shah Commission so far as the alleged case of under-\ninvoicing is concerned. In that case

SANKAR PATRO,GANJAM vs. INCOME TAX OFFICER, WARD-1, BERHAMPUR

In the result, appeal of the assessee is allowed

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

173 taxmann.com 582 (para 10 to 10.2). 3 iii) Order of ITAT Pune, in DCIT Vs. Kolte Patil Integrated Townships Ltd. ITA Nos. 2023 and 2011/PUN/2024 Dt.10.03.2025 (para 44 and 45). Copy of the above case laws are enclosed. PRAYER The assessee humbly pray that the reassessment notice u/s.148 of the IT Act dated 23.08.2022 is barred by limitation, illegal