BIHAR MEDICAL SERVICES AND INFRASTRUCTURE CORPORATION LIMITED,PATNA vs. DCIT, CIRCLE-1, PATNA

In the result, both the appeals preferred by the assessee are allowed for statistical purposes

Bench: the Assessing Officer to the notices issued by him. It is seen that even before the Ld. CIT(A), the assessee did not make any worthwhile presentation except that written submissions were filed in which it was mentioned that compliance could not be made before the Ld. Assessing Officer because a number of staff were suffering from COVID and hence were not alert enough to make proper representation before the Revenue Authorities. However, going by the fact that even before the Ld. CIT(A) ther

section 147 either in the recorded reason or in the sanction u/s 151. 9. For that the Ld. CIT(A) has erred in upholding the initiation of proceeding u/s 147/148 even though the same has been initiated on mere change of opinion. 10. For that the appellant reserves its right to furnish detailed written submission along with documents and evidences