2022 (1) TMI 1234

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....ior Advocate a/w Mr. Rahul Hakani. For the Respondents : Mr. Suresh Kumar. ORDER P.C. : 1. At the outset, in the order dated 10th January, 2022, in Paragraph No.1 the date "08/11/2021" be corrected and replaced with "12/11/2018". The original order to be corrected. Rest of the order remains unaltered. 2. Paragraph No.1 of the order dated 10th January, 2022 reads as under : ....

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....to notice dated 8th October, 2018, issued under Section 142(1) of the Act and petitioner has replied to, the same vide petitioner's letter dated 8th November, 2021. Dr. Shivram states that this issue has not been discussed in the assessment order but still relying on Aaroni Commercials Ltd. vs. Deputy Commissioner of Incometax -2(1) [(2014) 44 taxmann.com 304 (Bombay)] submitted that once a qu....

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....refore, it is a judgment of 2013 or earlier. The assessment order in this case has been passed on 15th December, 2018 and the query on this issue has been raised on 8th October, 2018 and replied by petitioner vide its letter dated 12th November, 2018. Therefore, the Assessing Officer had benefit of the judgment of the Delhi High Court relied upon by the Assessing Officer wanting to re-open the ass....