2023 (11) TMI 40

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.... Singhvi, Advocates. For the Respondents Through: Mr Gaurav Gupta, Sr. Standing Counsel with Mr Shivendra Singh, Mr Puneet Singhal and Ms Mahima Garg, Advocates. RAJIV SHAKDHER, J. (ORAL): CM APPL. 50190/2023 1. Allowed, subject to just exceptions. W.P.(C) 12722/2023 2. Issue notice. 2.1 Mr Gaurav Gupta, learned senior standing counsel, accepts notice on behalf of the respondent/revenue. ....

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.... the intimation dated 01.09.2023 issued under section 245 of the Act by Respondent No. 2 adjusting the refund due to Petitioner for assessment year 2022-23 against the (erroneous) disputed outstanding tax demand(s) for other assessments years, more particularly against demand for assessment year 2017-18 to the extent of Rs. 30,85,39,301; and c. directing the Respondents to expeditiously grant th....

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....o for AY 2017-18. 7. In sum, it is the petitioner's case that there has been a breach of principles of natural justice inasmuch as the respondents/revenue have moved away from what was proposed in the two emails referred to hereinabove. 7.1 The infraction of principles of natural justice is also sought to be buttressed by emphasising the point that although the petitioner was given twenty-one (2....