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Calcutta High Court

Apl Metals Ltd vs Addl Jt Dy Commissioner Income Tax ... on 15 March, 2024

Author: Hiranmay Bhattacharyya

Bench: T.S. Sivagnanam, Hiranmay Bhattacharyya

OD-3

                         IN THE HIGH COURT AT CALCUTTA
                     SPECIAL JURISDICTION [INCOME TAX]
                                   ORIGINAL SIDE

                                ITAT/83/2024
                              IA NO: GA/1/2024
                               APL METALS LTD
                                      VS
             ADDL JT DY COMMISSIONER INCOME TAX OFFICER AND ANR


BEFORE :
THE HON'BLE THE CHIEF JUSTICE T.S. SIVAGNANAM
            AND
THE HON'BLE JUSTICE HIRANMAY BHATTACHARYYA
DATE : 15TH MARCH, 2024.
                                                                               Appearance :
                                                                     Mr. J. P. Khaitan,Sr. Adv.
                                                              Mr. Riddhiman Mukherjee, Adv.
                                                                       Mr. P. P. Bishwal, Adv.
                                                               Ms. Suranjana Chatterjee, Adv.
                                                                                ..for appellant.
                                                                    Mr. Om Narayan Rai, Adv.
                                                              Mr. Soumen Bhattacharjee, Adv.
                                                                             ...for respondents.



       The Court :- Heard learned advocates on either side.

       The appeal requires to be heard and since the properties are voluminous it

would be conducive to take up the appeal in a physical mode hearing rather through

video conferencing. Therefore, we are inclined to fix the appeal for admission on 5th

April, 2024 in the admission list higher on board.

       The    learned senior counsel for     the     appellant submitted that         in   the

memorandum of appeal interim protection should be granted to the assessee since the

department has now issued a notice under section 226[3] of the Income Tax Act, 1961

to one of its customers namely, Exide Industries Ltd.

       Considering the fact that the order was passed by the tribunal on 15th

September, 2023 and till now the department had not initiated any action it is better
                                                2


that the department does not take any precipitative action pursuant to the impugned

order passed by the learned tribunal. Therefore, the notice issued under section 226[3]

of the Act dated 19.1.2024 to Exide Industries Ltd., the customer of the appellant be

kept abeyance till 12.4.2024 or until further order, whichever is earlier.

          As directed, list the matter for admission on 5th April, 2024.

          The learned advocate for the appellant is directed to communicate this order to

the department and the learned standing counsel shall also address the department in

this regard.



                                               .

(T.S. SIVAGNANAM) CHIEF JUSTICE (HIRANMAY BHATTACHARYYA,J.) pkd/GH.