2024 (11) TMI 173

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....esai, learned Senior Counsel representing 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 authorit....

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....ppeal before respondent No.4. Along with appeal, 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 Me....

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....te repeated query from the Bench, learned Standing 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 ra....