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    <title>2023 (9) TMI 724 - MADRAS HIGH COURT</title>
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    <description>Writ petitions challenging pre-assessment notices were not entertained at the show-cause stage because the limitation objection could be raised before the assessing authority. Interference under Article 226 at the notice stage is exceptional and is exercised sparingly where the controversy can be examined in the statutory proceedings. Limitation in this context was treated as a mixed question of law and fact, suitable for decision by the issuing authority after considering the petitioners&#039; objections and giving an opportunity of hearing. The petitioners were therefore left to pursue their objections before the assessing authority.</description>
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      <title>2023 (9) TMI 724 - MADRAS HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=443102</link>
      <description>Writ petitions challenging pre-assessment notices were not entertained at the show-cause stage because the limitation objection could be raised before the assessing authority. Interference under Article 226 at the notice stage is exceptional and is exercised sparingly where the controversy can be examined in the statutory proceedings. Limitation in this context was treated as a mixed question of law and fact, suitable for decision by the issuing authority after considering the petitioners&#039; objections and giving an opportunity of hearing. The petitioners were therefore left to pursue their objections before the assessing authority.</description>
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