2023 (11) TMI 1255

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....BLE MRS. JUSTICE SHUBHA MEHTA For the Appellant : Mr. Sanjeev Singhal For the Respondent : Mr. Shantanu Sharma with Ms. Bhavna Laddha and Mr. Anurag Mathur ORDER Learned counsel for the appellant presses this appeal on the proposed substantial questions of law which reads as under:- "i) Whether in facts and in the circumstances of the case Learned Income Tax Appellate Tribunal....

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....of Kanubhai M Patel HUF Vs. Hiren Bhatt or His Successors to Office & 4 respondent(s) reported in SCA/5295/2010 decided on 13.07.2010. From the record pleadings made by the appellant, it does not appear that the issue of limitation has been raised on a factual foundation that though notice under Section 148 of Income Tax Act, 1961 bears the date 31.03.2017, it was not issued on that date but it....