2025 (12) TMI 1715

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.... K. Patel for the respondents. 2. Rule returnable forthwith. Learned Senior Standing Counsel Mr. Varun K. Patel waives service of notice of Rule for the respondent. 3. The petitioner has prayed for the following reliefs :- "7(a) quash and set aside the impugned notices under Section 153C for AY 2010-11 and AY 2011-12 at Annexure-'A1' and A'2' respectively dated 30.06.2022, to this petition. (b) Pending the admission, hearing and final disposal of this petition, to stay assessment proceedings undertaken in consequence to the impugned notices u/s. 153C for AY 2010-11 and AY 2011-12 at Annexure-A1 and A'2' respectively" 4. The brief facts of the case are as under :- 4.1. The petitioner is Limited Company of which ....

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....ts objections against the proceedings vide communication dated 21.08.2023. The respondent no. 2 vide order dated 31.10.2023 disposed of the objections filed by the petitioner. It is the case of the petitioner that on 30.11.2023 the respondent no. 2 passed the Assessment Orders for Assessment Years 2012-13, 2013- 14 and 2015-16 to 2019-20 accepting the return of income of the petitioner without making any additions. It is the case of the petitioner that the assessment for Assessment Years 2010-11, 2011- 12 and 2014-15 continued and the petitioner filed replies to the notices issued by providing the necessary details sought for. 4.4. Thereafter on 15.01.2024 the petitioner raised objections to the validity of the notices as well as the con....

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....r Standing Counsel Mr. Varun K. Patel for the respondents has submitted that as per the decision of the Apex Court in the case of Jasjit Singh (supra), the Assessing Officer of the searched person has received the Jurisdictional Assessing Officer (JAO) of the assessee on 20.06.2022 for the Assessment Year 2023-24 and, hence is unable to controvert the facts as narrated in the writ petition and also the scope of the action of the respondent being outside the period of ten years as the income escaping the assessment is less than Rs.50,00,000/-. 8. Having heard the learned advocates for the parties, at this stage we may incorporate the relevant observations of the Apex Court in the case of Jasjit Singh (supra), which reads as under :- ....