2025 (11) TMI 1316

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....umar Singh, Rahul Agarwal For the Respondent(s) : Ankur Agarwal, Gaurav Mahajan, Krishna Agarawal ORDER 1. Heard Sri Rahul Agarwal learned Senior Counsel assisted by Sri Niraj Kumar Singh, learned counsel for the petitioner and Sri Ankur Agarwal, learned counsel for the revenue. 2. Challenge has been raised to the order dated 23.08.2023 first served on the petitioner vide email dated 3....

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.... ACIT, Circle- Moradabad DCIT (CC)-30, Delhi DLC-CC-46-14 Considering the facts of the case(s), order u/s 127 is passed accordingly. This order shall come into force with immediate effect. (Abha Kala Chanda) Pr. Commissioner of Income Tax Bareilly Dated:- 23/08/2023" 3. Also challenge has been raised to the reassessment notice issued to the petitioner by respondent no. 2 u....

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....ted 22.01.2025, the impugned transfer order dated 23.08.2023 was served on the petitioner through email on 31.01.2025. The petitioner did not act on the same. It has approached the Court with delay of more than six months. 8. The above objection has been met by learned Senior Counsel for the petitioner on the strength of reasoning that the transfer order is silent as to the A.Y. or the proceedi....

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....the transfer order whereby the reassessment proceedings for A.Y. 2022-23 came to be transferred, on a cogent reading of the impugned order dated 23.08.2023 and the reassessment notice dated 08.07.2025. The cause of action became complete and it crystalized only on issuance of the reassessment notice dated 08.07.2025, and not before. 10. Therefore the relevant date to test if the petition is hit....