2023 (7) TMI 33

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.... Sr. Advocate Ms. Kajal Sahoo, Advocate For the Opp. Parties: Mr. S.S. Mohapatra, Senior Standing Counsel (Revenue) ARINDAM SINHA, J. 1. Mr. Sahoo, learned senior advocate appears on behalf of petitioner-assessee. He submits, there was reassessment made on 31st March, 2022, whereby his client's income was added by Rs. 5,57,50,296/- under section 68 of Income Tax Act, 1961. His client pref....

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....tion 275 (1) (a) of the Act, had already expired. Aggrieved by the above order dated 20th July, 2017, the Petitioner went before the PCIT who, by the impugned order dated 2nd August, 2017, disposed of the application of the Petitioner by the following order sheet entry. "Present Sh. Vishal Rastogi, AGM of LG requested to make payment of 20% of the tax demand of 32Cr. Amounting to 6.4 Cr. ....

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....v. LG Electronics India Private Limited reported in (2018) 18 SCC 447. He submits, the Supreme Court declared that the administrative circular will not operate as a fetter on the Commissioner since, it is a quasi judicial authority. He submits further, the principle applies to the AO. In impugned letter, where the AO appears to be uncertain regarding filing of the appeal, he has acted mechanically....