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2019 (12) TMI 81

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....RI.GANGADHAR J M, ADV. RESPONDENT: SRI.Y V RAVIRAJ, ADV. ORDER The petitioner who is an assessee has assailed the demand at Annexure-'D' whereby the assessee has been called upon to pay Rs. 2,16,70,347/- with respect to financial year 2011-12, pursuant to survey proceedings under Section 133A(2A) of Income Tax Act, 1961. 2. It is stated that show cause notice came to be issued at Annex....

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.... the assessee to submit his reply. In light of the hearing itself being fixed on 22.03.2019 and petitioner himself receiving the notice on 23.03.2019 and also taking note of the said e-mail which was sent to the petitioner on 23.03.2019, the facts would make out a case that no sufficient opportunity for the petitioner to show cause as regards to the notice at Annexure-A, was afforded. 4. Learne....