Bench: Honourable The Chief Justice Honourable Mrs. Justice Susmita Phukan Khaund Judgment Date : 02-08-2023 (S.P. Khaund, J) 1. Heard Mr. S. Chetia, Learned Senior Standing Counsel, Income Tax Department & Mr. G.N. Sahewalla, Learned Senior Counsel For The Respondent Assisted By Learned Counsel Mr. M. Sahewalla. 2. This Is An Appeal U/S 260A Of Income Tax Act, 1961 (The I.T. Act For Short) Against The Order Dated 14.11.2018 Passed By The Income Tax Appellate Tribunal ‘E’ Court

4. The genesis of the case was that, there was a search and seizure operation u/s 132 of the I.T. Act in the case of the respondent Shyama Power Group India Ltd. from 25.02.2014 upto 18.03.2014. The respondent/assessee had already filed its original return of income for the Assessment Year 2011-2012 in time and time limit for issuance