2022 (6) TMI 571

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.....JUSTICE SENTHILKUMAR RAMAMOORTHY, J. For the Petitioner : Mr.G.Baskar For the Respondents : Mr.A.P.Srinivas, CGSC ORDER The petitioner assails the communication dated 21.04.2022 by which the objections raised by the petitioner to the reopening of the assessment were rejected. The petitioner asserts that the impugned communication is in contravention of the amended Section 148-A of the....

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....ded procedure is made applicable both in respect of notices issued prior to 01.04.2021 and subsequent thereto. The relevant paragraphs 26 and 27 are extracted below: "26. In view of the above and for the reasons stated above, the present Appeals are ALLOWED IN PART. The impugned common judgments and orders passed by the High Court of Judicature at Allahabad in W.T. No. 524/2021 and other ....

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....ed, with the prior approval of specified authority under section 148A(a) is hereby dispensed with as a onetime measure vis-à-vis those notices which have been issued under section 148 of the unamended Act from 01.04.2021 till date, including those which have been quashed by the High Courts. Even otherwise as observed hereinabove holding any enquiry with the prior approval of specif....

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....e and under which similar notices which were issued after 01.04.2021 issued under section 148 of the Act are set aside and shall be governed by the present order and shall stand modified to the aforesaid extent. The present order is passed in exercise of powers under Article 142 of the Constitution of India so as to avoid any further appeals by the Revenue on the very issue by challenging similar ....