2024 (12) TMI 1642

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....ROY, JJ. For the Petitioner : Pradeep Agrawal, Amar Mani Tiwari For the Respondent : Kushagra Dikshit ORDER 1. Heard. 2. The petitioner has already challenged the notice under Section 148A(b) of the Income Act, 1961 dated 15.03.2022, the order under Section 148A(d) of the Income Tax Act, 1961 and notice under Section 148 of the Income Tax Act, 1961 dated 29.03.2022 before the appell....

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....ed by the petitioner-appellant before it at the earliest but as per law and after hearing the Department, as, in the event jurisdictional issues are decided in favour of the petitioner then the appellate authority may not have to go to the merits of the issues unless of course there are compelling reasons to decide the jurisdictional issues along with the merits of the issues in that case the appe....