2026 (1) TMI 827

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....#39;BLE MR. JUSTICE DINESH MEHTA AND HON'BLE MR. JUSTICE VINOD KUMAR For the Petitioner Through: Mr. Salil Kapoor, Mr. Sumit Lalchandani, Ms. Ananya Kapoor and Mr. Anat Kapoor, Advs. For the Respondents Through: Mr. Siddhartha Sinha, SSC ORDER 1. By way of present Writ Petition, the petitioner has challenged the notice dated 11.07.2024 issued to the petitioner under Section 153C of....

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....roceedings under Section 153C of the Act of 1961, as provided in fourth proviso to Section 153A of the Act of 1961. 3. Explaining the delay in approaching the Court and arguing that there is none, learned counsel contended that in response to petitioner's request for providing satisfaction note, the respondent provided the same on 27.01.2025, whereafter the petitioner furnished a reply on 09.06....

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....he final order and concluding the proceedings, petitioner's objection even in relation to jurisdiction shall be considered by the AO. 6. Having heard learned counsel for the parties and upon consideration of material available on record, we are of the view that the petitioner-assessee has a plausible ground to resist or oppose the proceedings under Section 153C of the Act of 1961. The foundatio....