2019 (10) TMI 1375

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.... 1. Mr. Uchit Sheth, learned advocate for the petitioner inter alia submitted that though the impugned order is dated 29.3.2019, the same has been despatched only on 4.9.2019 and was received by the petitioner on 23.9.2019. It was submitted that the limitation for passing the said assessment order expired on 31.3.2019 and it appears that with a view to get over limitation, the impugned order is a....

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....t sub-section (1) thereof requires that prior to transfer of proceedings, the Commissioner after due notice to the concerned parties shall pass an order in writing. It was submitted that in this case no notice has been issued to the petitioner under sub-section (1) of section 17 of the Act and hence, the officer concerned had no jurisdiction to pass the impugned order. 3. It was further submitt....