PRINCIPAL COMNR. OF INCOME TAX, SAMBALPUR vs. M/S. BOUDH CO-OPERATIVE CENTRAL BANK LTD.

In the result, the appeal (APO/2/2023) is allowed and

Bench: : The Hon’Ble Acting Chief Justice T.S. Sivagnanam & The Hon’Ble Justice Hiranmay Bhattacharyya Date : 5Th April, 2023 Appearance : Mr. Pranit Bag Adv. Mr. Anujit Mookherji, Adv. ...For The Appellant Ms. Smita Das De, Adv. ...For The Respondent. The Court : This Intra-Court Appeal By The Writ Petitioner Is Directed Against The Order Dated 28Th November, 2022 In Wpo/2571/2022. The Appellant Had Filed The Writ Petition Challenging An Order Passed Under Section 148A(D) Of The Income Tax Act, 1961 (The ‘Act’) & The Consequential Notice Issued Under Section 148 Of The Act. The Learned Single Bench Dismissed The Writ Petition On The Ground That The Order Has Not Been Passed By An

Section 148A(b) of the Act none of these objections have been raised. Rather, the assessee has stated that the assessment order dated 22nd April, 2021 has attained finality when it is factually otherwise. One other submission which has been made by the learned Advocate for the appellant is that the addition which is now contested by the appellant before