2023 (6) TMI 978

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.... P.C.: 1. Petitioner is impugning a notice dated 29th March 2019 issued under Section 148 of the Income Tax Act, 1961 (the Act) and the order disposing objections dated 15th November 2019. 2. Mr. Gandhi stated that the reopening notice was issued after the expiry of four years of the assessment year but was candid to say that this was a case where no order under Section 143(3) of the Act ha....

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.... have been discussed in the order disposing the objections. 5. In the circumstances, we quash and set aside the order dated 15th November 2019 disposing the objections and remand the matter for denovo consideration to the Jurisdictional Assessing Officer (JAO). 6. In our order dated 5th June 2023, paragraph 2 reads as under : 2. At Exhibit L to the affidavit in reply filed through o....

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....ade available to him is only the form for recording the reasons for initiating proceedings under Section 148 of the Act and for obtaining the approval of the Principal Commissioner of Income Tax but the document this Court had directed respondents to provide has not been provided. 8. Since we are disposing the petition, we are not taking any action against respondents for not obeying the order ....

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....all be a reasoned order dealing with every submission of petitioner. If respondent no. 1 is going to rely on any judgments or orders passed by any Court or Tribunal in his order disposing the objections, a list thereof shall be provided to petitioner alongwith notice of personal hearing so that petitioner will be able to deal with those judgments/distinguish those judgments. 10. If the document....