Principal Commissioner Of Income vs Indian Metals & Ferro Alloys Ltd
2023 Latest Caselaw 11915 Ori

                                 IN THE HIGH COURT OF ORISSA AT CUTTACK
                                              ITA No.145 of 2018

                        Principal Commissioner of Income      ....         Appellant
                        Tax -1, Bhubaneswar
                                         Mr.T.K. Satapathy, Senior Standing Counsel
                                                 -versus-
                        Indian Metals & Ferro Alloys Ltd.,    ....       Respondent
                        Bhubaneswar
                                                                  Mr. S. Jolly, Advocate
                                   CORAM:
                                   DR. JUSTICE S.K. PANIGRAHI
                                   MR JUSTICE G. SATAPATHY
                                                    ORDER

03.10.2023 Order No.

10. 1. This matter is taken up through hybrid arrangement.

2. Heard learned counsel for the parties.

3. Admit.

4. After hearing of the parties, this Court is of the view that the

following substantial question of law requires consideration:

i) Whether the learned Tribunal was rightly set aside the reassessment order dated 13.03.2015 passed under section 147/143(3) of the I.T. Act treating the reasons recorded by the Assessing Officer as "change of opinion"?

5. Hearing is concluded. Judgment/order is reserved.

(Dr.S.K.Panigrahi) Signature Not Verified Judge Digitally Signed Signed by: KISHORE KUMAR SAHOO Designation: Secretary Reason: Authentication Location: High Court of Orissa Date: 03-Oct-2023 17:18:56 (G.Satapathy) Judge Kishore