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2024 (9) TMI 1338

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....d counsel for the parties. This petition under Article 226 of the Constitution seeks a relief that a notice issued to the petitioner under Section 148A(b) dated 19 March 2024 and the order dated 8 April 2024 passed under Section 148A(d) of the Income Tax Act, 1961, and consequent thereto the notice issued to the petitioner under Section 148 dated 8 April 2024 be quashed and set aside. There is an ....

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.... mechanism as provided under the provisions of Section 144(B) read with Section 151A and the "Scheme" notified by the Central Government dated 29 March 2022 under Section 151A. It is also correct that in several proceedings which had come up before this Court, the Court had taken into consideration the said decision and had granted reliefs, finally disposing of the petitions. 3. In considering th....

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.... would stop rolling. This, in as much as, the decision of this Court in Hexaware, being already assailed by the Revenue before the Supreme Court, it is stated by Mr. Sharma, that all our judgments which follow the decision in Hexaware and the other connected decisions, are now being assailed by the Revenue before the Supreme Court, in the proceedings of a Special Leave Petition being filed under A....

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....r litigation between the Revenue and the assessees. We may observe that the endeavor of the Court would always be, that at least, the orders passed by the Court ought not to generate any litigation between the parties much less a further litigation with which we are concerned. In fact, the endeavor of the Court would be that the litigious issues achieve a quietus. This is however only a passing th....