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2019 (2) TMI 909

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....ises against the Assessment Order dated 26.12.2018 passed by the respondent No.1 under Section 143(2) read with Section 147 of the Income Tax Act, 1961 ('Act' for short) relating to the Assessment Year 2011-12 and the consequential demand notice dated 26.12.2018 as well as the directions dated 28.11.2018 issued under Section 144A of the Act by the respondent No.2. 2. In order to appreciate the co....

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....ection 144A of the Act before the respondent No.2 seeking directions. Accordingly, respondent No.2 passed an order on 28.11.2018 issuing directions to the respondent No.1, the relevant direction reads as under:- "The assessee has also credited other receipts on various dates amounting to Rs. 1,07,025/-, the sources of these receipts are not known. Further, it is also not clear whether the amount....

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.....2, the respondent No.1 concluded assessment proceedings and an order has been passed on 26.12.2018 after providing an opportunity of hearing to the petitioner and considering the objections filed. 5. Learned counsel Smt.Vani H., appearing for the petitioner placing reliance on the Division Bench judgment of this Court in the case of M/s. Deepak Extrusion Pvt. Ltd., vs. The Deputy Commissioner of....

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....ons to respondent No.1 during the pendency of the reassessment proceedings under Section 143(3) read with Section 147 of the Act. It is hardly required to be stated that the respondent No.1 is bound by the directions issued by the respondent No.2 in terms of the order passed under Section 144A of the Act. That being the fact situation, the order impugned is passed by respondent No.1. It is the gri....