Mrs. Neelam Agrawal , Kolkata vs Ito, Ward-37(1), Kolkata on 22 July, 2024
vi) Shyam Sundar Dhanuka Vs. Union of India [2023] 156
taxmann.com 499 (Cal) and
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39. The judgment of the Hon'ble Division Bench in the case of Shri Shyam
Sundar Dhanuka (supra) relied on by Mr. Dutt has been rendered in the
peculiar facts of the case where a factual enquiry was needed. It was not a
case of change of opinion but a case where "deeper probe into the matter was
required". The matter at hand is a clear and apparent case of change of
opinion.
Dinesh Kumar Goyal Huf vs Income Tax Officer Ward-43(1) on 17 November, 2023
In support of this contention, Mr.
Bhattacharyya, learned standing counsel for the
department placed reliance of this court in Shri Shyam
4
Sundar Dhanuka v. Union of India and Others reported
in APOT 187 of 2023 dated 30.08.2023 and the
decision of the Hon'ble Division Bench of the High
Court at Telengana in the case of Yelliah Setty v.
assistant Commissioner of Income-tax reported in
[2022] 143 Taxmann.com 326 (Telengana).
1