2022 (3) TMI 1517

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.... the Respondents : Mr. T.K. Satapathy, Senior Standing Counsel ORDER 1. These two appeals are directed against the corresponding orders of the Income Tax Appellate Tribunal, Cuttack Bench, Cuttack (ITAT) dated 15th October 2019 in ITA Nos.464 and 465/CTK/2017 for the assessment year (AY) 2009-10 and 2010- 11. 2. While admitting these appeals on 10th November 2021, the following questions ....

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.... stage. 4. In response, Mr. Ray, learned counsel for the Appellant draws attention of this Court to the following observations of the Supreme Court of India in Saurav Jain v. A.B.P. Design AIR 2021 SC 3673: "34. Based on the position of law, we find it just to allow the appellant to raise the ground of jurisdiction before us. Allowing the ground to be raised would not require the submi....

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....f Income Tax v. Shri Jay Shiv Shankar Traders Pvt. Ltd. (2016) 383 ITR (Del) 448 and the order dated 25th February 2022 of this Court in ITA No.20 of 2017 (Principal Commissioner of Income Tax, Bhubaneswar v. Orissa Mining Corporation Ltd.). 7. With the admitted position being that on facts in the present case, notice under Section 143 (2) of the Income Tax Act, 1961 (Act) was not issued to the....