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of <h1>Earlier precedent governs reassessment challenges arising from searches before 01.04.2021, so petition was decided as covered by precedent</h1> <h3>M/s Shiv Vegpro Private Limited Versus The Deputy / Assistant Commissioner Of Income Tax, Circle-2, Kota, Central Board Of Direct Taxes, New Delhi</h3> HC held that the challenge to reassessment proceedings initiated on the basis of a search conducted prior to 01.04.2021 is governed by an earlier HC ... Re-assessment proceedings on the basis of search carried out prior to 01.04.2021 - HELD THAT:- Taking into consideration that the challenge to the order is based mainly on the ground that present is a case pertains to proceedings of re-assessment on the basis of search carried out prior to 01.04.2021, the issue raised in this petition stands covered by the aforesaid order passed in the case of Tirupati Construction Company [2024 (5) TMI 1170 - RAJASTHAN HIGH COURT]. Heard. Parties jointly submitted that the issue is 'no longer res integra' and stands concluded by the Division Bench order dated 21.03.2024 in Tirupati Construction Company Vs. Income Tax Officer [(2024) 465 ITR 611 (Raj)]. The petition challenged reassessment proceedings instituted on the basis of a search carried out prior to 01.04.2021. Having examined the relief sought, factual background and the issue involved, the Court held that the challenge is covered by the aforesaid Division Bench decision. Applying that precedent, the petition was allowed and the impugned order(s) were quashed.
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