2016 (4) TMI 561

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....the request of the parties, the petition is disposed of finally at the stage of admission. 2. This petition under Article 226 of the Constitution of India challenges the Notice dated 27th March, 2015 issued under Section 148 of the Income Tax Act, 1961 (the Act). The impugned notice dated 27th March, 2015 seeking to reopen the assessment for A.Y. 2008-09. 3. The petitioner's grievance is tha....

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....under Section 143(3) of the Act. The reasons in support of the notice refer to various issues which fall in the aforesaid two classes. The petitioner also filed an exhaustive objection to the reasons recorded on 15th March, 2015 pointing out that the reasons in support of the impugned notice do not indicate that the Assessing Officer has jurisdiction to issue the impugned notice under Section 148 ....

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....x Officer, 259 ITR 90. In fact, the entire procedure of an assessee objecting to the reasons in support of the impugned notice recorded by the Assessing Officer is to ensure that the Assessing Officer has second look at the reasons recorded by him on consideration of the objections. This procedure has been evolved so that if the Assessing Officer is satisfied with the objections put forth by the a....