NEELACHAL I.NIGAM L. vs. ASST.COMNR.OF I.TAX
ITA/8/2005HC Orissa17 Nov 2021
Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE ADITYA KUMAR MOHAPATRA
Section 143(1)(a)
Sections 147/148 of the IT Act.
Consequently, the answer to this question is given in favour of
assessee to hold the decision of AO to reassess the assessee was
not independent but was at the instance of superior officer.
42.
Now next coming to the substantial questions of law which were
admitted for hearing at the instance of Revenue