ACIT,CIRCLE-1(!), SAMBALPUR vs. M/S. TRL KROSAKI REFRACTORIES LIMITED, JHARSUGUDHA

In the result, appeals of the revenue for the assessment years 2010-

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No.260 260/Ctk/2020: Assessment Year Assessment Year :2010-2011

8. It was submitted by ld CIT DR that the ld CIT(A) had quashed the assessment orders for all the assessment years on the ground that no draft assessment orders had been passed u/s 144 C of the Act in respect of additions made under section 92CA of the Act. It was the submission that show cause notice

ACIT,CIRCLE-1(1), SAMBALPUR, SAMBALPUR vs. M/S. TRL KROSAKI REFRACTORIES LIMITED, JHARSUGUDHA

In the result, appeals of the revenue for the assessment years 2010-

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No.260 260/Ctk/2020: Assessment Year Assessment Year :2010-2011

8. It was submitted by ld CIT DR that the ld CIT(A) had quashed the assessment orders for all the assessment years on the ground that no draft assessment orders had been passed u/s 144 C of the Act in respect of additions made under section 92CA of the Act. It was the submission that show cause notice

ACIT,CIRCLE-1(1),, SAMBALPUR vs. M/S. TRL KROSAKI REFRACTORIES LIMITED, JHARSUGUDHA

In the result, appeals of the revenue for the assessment years 2010-

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No.260 260/Ctk/2020: Assessment Year Assessment Year :2010-2011

8. It was submitted by ld CIT DR that the ld CIT(A) had quashed the assessment orders for all the assessment years on the ground that no draft assessment orders had been passed u/s 144 C of the Act in respect of additions made under section 92CA of the Act. It was the submission that show cause notice

ACIT,CIRCLE-1(1), SAMBALPUR vs. M/S. TRL KROSAKI REFRACTORIES LIMITED, JHARASUGUDHA

In the result, appeals of the revenue for the assessment years 2010-

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No.260 260/Ctk/2020: Assessment Year Assessment Year :2010-2011

8. It was submitted by ld CIT DR that the ld CIT(A) had quashed the assessment orders for all the assessment years on the ground that no draft assessment orders had been passed u/s 144 C of the Act in respect of additions made under section 92CA of the Act. It was the submission that show cause notice

ACIT(CIRCLE-1(1),, SAMBALPUR vs. M/S. TRL KROSAKI REFRACTORIES LIMITED, JHARSUGUDHA

In the result, appeals of the revenue for the assessment years 2010-

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaita No.260 260/Ctk/2020: Assessment Year Assessment Year :2010-2011

8. It was submitted by ld CIT DR that the ld CIT(A) had quashed the assessment orders for all the assessment years on the ground that no draft assessment orders had been passed u/s 144 C of the Act in respect of additions made under section 92CA of the Act. It was the submission that show cause notice

ITO, ANGUL WARD, , ANGUL vs. M/S. NCC SMASL JRT(JV),, ANGUL

transfer the entire sale proceeds to AE to ensure lowest sale price to MC. The assessee failed to justify the rationality of the approach since, the ultimate sale price to MCL is not linked with the cost of either assessee or AE in the entire scheme of arrangement. Further, the assessee's contention that the income of the assessee

ITO, ANGUL WARD, ANGUL vs. NCC-SMASL-JRT(JV), ANGUL

transfer the entire sale proceeds to AE to ensure lowest sale price to MC. The assessee failed to justify the rationality of the approach since, the ultimate sale price to MCL is not linked with the cost of either assessee or AE in the entire scheme of arrangement. Further, the assessee's contention that the income of the assessee