2024 (11) TMI 173

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....ing Sri M.Pranav, learned counsel for the petitioner and Sri A.Rama Krishna Reddy, learned Counsel representing Sri A.Radha Krishna, learned Senior Standing Counsel for respondent-Income Tax Department. 2. With the consent, finally heard. 3. This petition filed under Article 226 of the Constitution of India assails the order of learned appellate authority dated 07.08.2024. 4. The background fac....

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....l, the petitioner preferred application for stay. The said application was partly allowed by directing the petitioner to deposit 20% of the demand i.e. Rs. 69,71,75,824/-. 6. The bone of contention of learned Senior Counsel for the petitioner is that the learned appellate authority was totally guided by Central Board of Direct Taxes (CBDT) Office Memorandums dated 29.02.2016 and 31.07.2017 and on....

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.... Counsel is unable to show any iota of discussions/application of mind about aforesaid notifications (Annexures-P.9 and P.10) in the impugned order. 8. Prima facie reading of Annexures-P.9 and P.10 shows that petitioner could make out a prima facie case. Sadly, the appellate authority has not taken any pain to consider the singular contention raised by the petitioner based on these notifications.....