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CALCUTTA HIGH COURT
Om Narayan Rai, J
Balmer Lawrie And Company Limited – Appellant
Versus
Union of India – Respondent
| Table of Content |
|---|
| 1. background on reassessment appeal. (Para 1 , 2) |
| 2. petitioner's arguments against reassessment. (Para 3 , 4 , 5) |
| 3. court's analysis of legal information provided. (Para 6 , 7 , 8 , 9 , 10) |
| 4. inconsistency in assessing officer's reasoning. (Para 11 , 12 , 13 , 14) |
| 5. no material indicating income escaping assessment. (Para 15 , 16 , 17 , 18) |
| 6. judicial precedence on reassessment authority. (Para 19 , 20 , 21) |
| 7. allowing jurisdictional intervention under article 226. (Para 22 , 23 , 24) |
| 8. invocation of section 147 procedure. (Para 25 , 26) |
| 9. reassessment order set aside with conditions. (Para 27 , 28 , 29) |
| 10. final conclusion and order from the court. (Para 30 , 31) |
Om Narayan Rai, J.:-
1. This writ petition has been filed assailing proceedings for reassessment of the petitioner’s income for the Assessment Year 2019-20.
FACTS OF THE CASE:
2. A brief summary of the facts gathered from the writ petition may first be noticed:-
a) The petitioner is a Government company. It is under the control of the Ministry of Petroleum and Natural Gas, Government of India and is classified as a category-I, Miniratna Company.
b) Of the several businesses which the company conducts, one is to
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