2025 (2) TMI 1254

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....SUNDAR AND HONOURABLE MR JUSTICE C. SARAVANAN For the Appellant(s): M/s. A.P. Srinivas, A.N.R. Jayaprathap. For the Respondent(s): M/s. R. Sivaraman, P. Ramesh Kumar, S. Srividhya, Raghav Rajeev Menon, Vandana Vyas Caveator For R1. JUDGMENT (HON'BLE S.S. SUNDAR J.) 1. This writ appeal is directed against the order of the learned Single Judge dated 25.04.2024 in WP. No. 2357/2024....

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....e [iv] of Explanation to Section 245A of the Income Tax Act, 1961, is contrary to the judgment of the Division Bench of this Court in Jain Metal Rolling Milss Vs. Union of India in WP.No.13455/2021 and batch and the judgment of Division Bench dated 26.03.2024 in Ashwini Fisheries Private Limited Vs. Principal Commissioner of Income Tax and Others, wherein it is held that applications in respect of....