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2025 (6) TMI 985

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....r the Petitioner: Mr. Jeet Kamdar i/b Ganeshmurthy, Advocates. For the Respondents: Mr. Akhileshwar Sharma, Advocates. P. C. 1. By this Petition, the Petitioner is aggrieved by the final assessment order dated 30th September 2021 ('impugned order') passed by Respondent No. 1 on the ground that the said assessment order has been passed in violation of the provisions of section 144B of the Act....

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....es on 25th October 2016 and it was found that JSK Group had taken huge unsecured loans from various entities including the Petitioner. Subsequently, notices dated 1st September 2021, 3rd September 2021 and 10th September 2021 were issued under section 142 (1) of the Act which were replied to on 21st September 2021. 3. A show cause notice was issued on 28th September 2021 granting an opportunity t....

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.... The learned Counsel for the Petitioner submits that the final assessment order dated 30th September 2021 passed by the assessing officer is without jurisdiction in as much as the same has been passed without serving upon the Petitioner a draft assessment order as envisaged under section 144B (1) (xvi) of the Act. The issuance of a draft assessment order is mandatory in terms of the Faceless Asses....

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.... and time given to reply was till 29th September 2021 and the assessment order was passed on 30th September 2021. Mr. Akhileshwar Sharma, the learned Counsel for the Respondents, agrees that the show cause notices granted just one days time to the Petitioner to furnish its response. 7. In view of the above, it is apparent that the Respondents have acted in violation of the principles of natural j....