2021 (8) TMI 788

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....nt ORDER In this matter petitioners have challenged the impugned notices dated 29th May, 2021 and 18th June, 2021 relating to assessment years 2014-15 and 2015-16 respectively under Section 148 of the Income Tax Act, 1961 on the ground that before issuing notice under Section 148 of the Act, mandatory provisions of Section 148A of the Act which cast statutory obligation on the Assessing Officer....

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....issioner of Income Tax 14(1) (2), Mumbai & Ors. He has also relied on one reported decision of Hon'ble Bombay High Court in WP(L) No. 14687 of 2021 in the case of Sahil International Vs. Assistant Commissioner of Income Tax, Circle-19(3) & Ors. reported in [2021] 128 taxmann.com 161 (Bombay) dated 9th July, 2021 and one unreported decision of Hon'ble Delhi High Court in W.P.(C) 6176 of 2021 in the....

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....tice under Section 148 of the Act, provisions under Section 148A was complied with or not. Mr. Bhowmik says that officer concerned has asked for further time and was not able to deny the allegations of the petitioners that Section 148A provisions of the Income Tax Act, 1961 was not complied with in this case before issuing notice under Section 148 of the said Act and was not able to distinguish th....