2025 (4) TMI 298

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....ah,. For the Respondents: Ms Shilpa Goel,. PC:- 1. Heard learned Counsel for the parties. 2. The challenge in this Petition concerns the order giving effect dated 7 February 2020 passed by the 1st Respondent for the Assessment Year 2008-2009. 3. The Petitioner, in paragraph 17 of the Petition, has admitted that the impugned order is appealable. But the Petitioner has pleaded, and th....

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.... alternate remedy. 5. Ms Goel learned counsel for the Respondents submits that this was a case of remand by the ITAT and, in such circumstances, there was no requirement of again furnishing a draft Assessment Order. She pointed out that the draft Assessment Order was supplied in the earlier round. She also pointed out that the limitation period must be construed by making allowances for the tim....

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....isions relied upon by the Petitioner, the Respondents offered a concession, and based upon such concession, this Court remanded the matters. However, nothing in the earlier decisions indicates that the objection regarding the exhaustion of alternate remedies was raised or decided by this Court. 8. Mr Savla learned counsel for the Petitioner relief upon a judgment of the Hon'ble Supreme Court in....

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.... this factor should the Petitioner institute an Appeal within four weeks from today. 10. The Petition is disposed of with liberty in the above terms. No costs. 11. Should the petitioner institute an appeal against the impugned order, the Assessing Officer will decide on all contentions of all parties. 12. After this order was dictated, learned counsel for the Petitioner, based on instruct....