TaxTMI 
TaxTMI 
2023 (10) TMI 410
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....EF JUSTICE AND HIRANMAY BHATTACHARYYA, J. For the Appellants : MR. Ankit Kanodia, Ms. Megha Agarwal, Mr. Jitesh Sah. For the Appellants : Md. T.M. Siddiqui, Mr. T. Chakraborty, Mr. S. Sanyal. 1. These intra court appeals are directed against the orders passed by the learned Single Bench dated 17th July, 2023 in WPA 13343 of 2023 and WPA 13349 of 2023. 2. The issue involved in both the ....
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.... undisputed fact is that the rebuttal could not be filed. However, the assessee would explain that there was an application pending before the Special Commissioner and that is the reason for which the appellants/assessees did not file their rebuttal to the preliminary report. As pointed out earlier, the final report has already been drawn and based on that an intimation to show cause was issued in....
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....show cause notice, it has come on record that subsequently a show cause notice has already been drawn on 23.8.2023. On perusal of the said show cause notice, it cannot be stated that there has been any pre-judging of the matter as the show cause notice takes into account the allegations which were brought about in the final report and thereafter the authority has proceeded to issue the show cause ....
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....how cause notice dated 23.08.2023. 11. Therefore, we are of the considered view that the appellants should participate in the adjudicating proceedings by filing an appropriate reply to the show cause notice dated 23.08.2023. 12. In reply to the show cause notice, the appellants are entitled to raise all factual and legal issues including the issue that the Bureau of Investigation cannot act or f....