2023 (11) TMI 40

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....r Aniket D. Agrawal and Mr Abhishek 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, accep....

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....tant violation of the statutory mandate; and b. quashing 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,....

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....ted demands not only for AY 2018-19, which was one of the proposals, but also 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 buttress....