Ms Sarada Mines Pvt Ltd vs State Of Orissa And Others on 20 April, 2017
With regard to the case of State of Orissa v. Durgadutta
Moda (supra), cited by the Revenue it can also be said that the same is
factually distinguishable. In the present case, the allegation of under-
assessment is based on mere change of opinion based on three artificial
parameters like abysmal low price, peculiar business module being
followed by the petitioner and a suspicion relating to 100% output of
input. While the parameter of abysmally low price is not backed by fact,
suspicion relating to impossibility of 100% output is not backed by
scientific study.