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

37,71,766/- and the balance amount of Rs. 13,21,43,094/- was outstanding as on 31.03.2014. During the course of search and investigation, it was found that the assessee failed to deduct tax at source in respect of the amount which remained outstanding as on 31.03.2014. The credit balance of Rs. 13,21,43,094/- in the account