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Calcutta High Court

Principal Commissioner Of Income Tax vs M/S. Qualitron Commodities (P) Ltd on 20 July, 2022

Author: T.S. Sivagnanam

Bench: T.S. Sivagnanam

OD-12


                  IN THE HIGH COURT AT CALCUTTA
                 SPECIAL JURISDICTION (INCOME TAX)
                           ORIGINAL SIDE


                           ITAT/41/2021
                         IA NO: GA/2/2021
        PRINCIPAL COMMISSIONER OF INCOME TAX-1, KOLKATA
                                VS.
               M/S. QUALITRON COMMODITIES (P) LTD.




BEFORE :
THE HON'BLE JUSTICE T.S. SIVAGNANAM
         And
THE HON'BLE JUSTICE BIVAS PATTANAYAK
Date : 20th July, 2022.


                                 Appearance :-
                                 Mr. Vipul Kundalia, Adv.
                                 Mr. Anurag Roy, Adv.
                                                        ....for appellant.




        The Court:- We have heard Mr. Vipul Kundalia, learned

Standing Counsel appearing for the appellant.

        The appeal is admitted on the following substantial questions of

law:-

   (a) Whether in the facts and circumstances and law point of the

         case, the Learned Tribunal has erred in its judgement that 'no

         addition could have been made u/s 68 of the Act because the

         money in question was received in earlier years and not in the

         relevant assessment year under consideration' contradicts the
                                       2



         reason for selection of this case under scrutiny through CASS

         and "Large Share Premium received" during this year ?

     (b) Whether the Learned Tribunal was correct in observing that

         the assessment is held to be invalid and bad in law and

         without valid jurisdiction since the A.O. has finalized the order

         hurriedly by serving notices through affixture at the last

         available   address   and   notices   to    the   Director   through

         mail/speed post?

     (c) Whether the orders of the learned Tribunal dated 21st August,

         2018 is totally perverse and bad in law?

         The appellant shall file requisite numbers of informal paper

books prepared out of Court within eight weeks from date serving

copies thereof to the learned Advocate for the respondent. List the

appeal for hearing after ten weeks.

Settlement of index and all other formalities are dispensed with. The learned Advocate for the appellant shall serve notice of this appeal to the learned Advocate for the respondent.

The application for stay stands closed.

(T.S. SIVAGNANAM, J.) (BIVAS PATTANAYAK, J.) SN/GHAR(CR)