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2022 (2) TMI 1336

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.... (Judgement / Order / Decisions)<br>Dated:- 2-2-2022<br>WRIT PETITION No. 13646/2021 (T-IT) - -<br>Income Tax<br>THE HON&#39;BLE MR.JUSTICE S. SUNIL DUTT YADAV For the Petitioner : Sri Kali Vohra , Senior Advocate for Smt. Manasa Ananthan , Advocate For the Respondents : Sri K. V. Aravind , Advocate ORDER The petitioner has sought for declaration that the proceedings initiated by the ....

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....has received the copy of the order on 29.12.2016. The time period for completion of assessment proceedings in terms of Section 153(3) would be nine months from the end of Financial Year in which, order under Section 254 is received by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner or, as the case may be. If that were to be so, the order was require....

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....he notice of TPO is dated 09.07.2021 as per Annexure-L. Clearly, on the admitted period available as discussed above, the notice is beyond the time prescribed and is the one barred by limitation and is liable to be set aside on that sole ground alone. 5. What needs to be noticed is that the proceedings were restored back to TPO/AO/DRP in terms of the order dated 03.11.2016. Learned Senior Couns....