2024 (8) TMI 568

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....uj Jhaveri, Prakhar Pandey a/w. Mihir Modi i/b. Anuj Jhaveri. For the Respondent : Mr. Venkataraman N., ASG a/w. Mr. Akhileshwar Sharma. P.C. 1. We have heard Mr. Mistri, learned Senior Counsel for the Petitioner and Mr. Venkataraman, learned ASG on the present proceedings. The proceedings were listed for admission and interim reliefs. 2. During the course of hearing, issues of interpr....

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....Section 153 applies to the proceedings under Section 144C. Also there is one more decision of the Division Bench of the Madras High Court in The Commissioner of Income Tax & Anr. Vs. M/s. Roca Bathroom Products Private Limited (2022) 445 ITR 537 (Mad) taking a similar view. Both these decisions were referred to and relied on behalf of the parties. There was quite a debate at the bar on such decisi....

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....rein are in question." (emphasis supplied) 5. On behalf of the Revenue, Mr. Venkataraman, the learned ASG has made elaborate submissions. He has also placed on record written submissions. It is Mr .Venkataraman's endeavour to persuade us as to what would be the actual purport of the provisions of Section 144C read with Section 153 and Section 92CA of the Act to contend that as the prov....