2025 (1) TMI 1503

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....i/b. Lumiere Law Partners. For the Respondent: Mr. Abhishek Mishra. ORAL JUDGMENT:- (PER M. S. SONAK, J.) 1. Heard learned counsel for the parties. 2. Rule. The Rule is made returnable immediately at the request of and with the consent of the learned counsel for the parties. 3. The Petitioner complains against the adjustment of refund of an amount of Rs. 4,91,45,369/- against the....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....dents regarding objections to the proposed adjustments. There was no consideration of these objections. The petitioner was granted no opportunity of a hearing. No formal order was also made dealing with the petitioner's objections. All this violates the principles of natural justice. 6. In Hindustan Unilever Ltd. vs. Deputy Commissioner of Income-tax-1(1) [2015] 60 taxmann.com 326 (Bombay). The....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....gly, we quash the adjustments made in the purported exercise of powers under Section 245 of the IT Act and direct the Respondents to deposit an amount of Rs. 4,91,45,369/- in this Court within two weeks from today. The Registry should invest this amount in a nationalised bank and it will abide by the orders of the Respondents under Section 245 of the IT Act after giving reasonable opportunity of h....