2024 (7) TMI 223

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....For the Petitioner : Mr. G. Baskar Mr. I. Dinesh For the Respondent : Mr. A. P. Srinivas , Senior Standing Counsel ORDER An assessment order dated 30.03.2024 is assailed in this writ petition primarily on the ground that digital evidence was relied upon without complying with the Digital Evidence Investigation Manual issued by the Central Board of Direct Taxes. 2. Pursuant to a search ....

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....ance with the Digital Evidence Investigation Manual. In this case, learned counsel submits that digital evidence was not collected in accordance with the manual. By relying on a judgment of this Court in Saravana Selvarathnam Retails (P) Ltd. v. Commissioner of Income-Tax Appeals, [2024] 160 taxmann.com 287 (Madras), learned counsel submits that this Court held that the manual referred to above fa....

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.... justice were complied with in as much as the petitioner was provided opportunities to respond to notices and was heard before the impugned assessment order was issued. He further submits that the impugned assessment order was based on appraisal of evidence and that no case is made out for interference under Article 226 of the Constitution of India. 5. While the petitioner asserts that the resp....