2014 (5) TMI 593

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....ners : Dr. Anita Sumanth for Mr. V. Sanjeevi For the Respondent : Mr. Pramod Kumar Chopra, Standing Counsel for Income Tax ORDER Mr. Pramod Kumar Chopra, learned standing counsel for income tax takes notice for the respondent. 2. In W.P. No.13164/14, challenge is made to the notice dated 25.3.13, which calls upon the assessee intimating that the assessable tax of the year 2007-2008 has....

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.....13164/14 is concerned, the plea of the learned counsel for the petitioner is that the notice dated 25.3.13, has been issued only on 9.4.14 and, therefore, the same is beyond limitation. Learned standing counsel for the respondent, however, states on instructions that the allegation made by the petitioner is denied. It is submitted that notice was issued in time, however, belatedly received by the....

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....sment made is a protective assessment to find out the taxable nature of the transaction be it 2007-2008 or 2008-2009. In any event the assessment order 2008-2009 is appealable.  8. In such view of the matter, the assessment order can be assailed in appeal. Therefore, the petitioners have not made out a case for invoking the extraordinary jurisdiction of this court under Article 226 of Cons....