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    <title>Jurisdictional challenge to SCNs under PFUTP barred as delay tactics; issues to be decided together under Order XIV Rule 2(2)</title>
    <link>https://www.taxtmi.com/highlights?id=90699</link>
    <description>The HC dismissed the jurisdictional challenge to the impugned SCNs alleging breach of PFUTP Regulations and barred by res judicata and issue estoppel, holding that the petitions were a tactical attempt to delay adjudication. The Court found no merit in treating objections to the SCNs as preliminary issues, especially given the mixed questions of law and fact involved, which under Order XIV Rule 2(2) and settled principles are ordinarily not decided preliminarily. The petitions were filed belatedly, nearly two years post issuance of the SCNs, with successive delay tactics employed. The Court refrained from deciding the substantive merits, emphasizing that all issues, including those raised by petitioners, must be decided expeditiously and co.....</description>
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    <pubDate>Mon, 21 Jul 2025 08:43:52 +0530</pubDate>
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      <title>Jurisdictional challenge to SCNs under PFUTP barred as delay tactics; issues to be decided together under Order XIV Rule 2(2)</title>
      <link>https://www.taxtmi.com/highlights?id=90699</link>
      <description>The HC dismissed the jurisdictional challenge to the impugned SCNs alleging breach of PFUTP Regulations and barred by res judicata and issue estoppel, holding that the petitions were a tactical attempt to delay adjudication. The Court found no merit in treating objections to the SCNs as preliminary issues, especially given the mixed questions of law and fact involved, which under Order XIV Rule 2(2) and settled principles are ordinarily not decided preliminarily. The petitions were filed belatedly, nearly two years post issuance of the SCNs, with successive delay tactics employed. The Court refrained from deciding the substantive merits, emphasizing that all issues, including those raised by petitioners, must be decided expeditiously and co.....</description>
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      <pubDate>Mon, 21 Jul 2025 08:43:52 +0530</pubDate>
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