2025 (8) TMI 1769

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....itioner : Mr. Sanjay Bansal, Sr. Advocate with Mr. Gurdeep Singh, Advocate For the Respondents-Income Tax Department : Ms. Gauri Neo Rampal, Sr. Standing Counsel Mr. Akshay Mittal, Jr. Standing Counsel ORDER LISA GILL, J. 1. Learned counsel for petitioner submits that notice dated 22.03.2025, issued under Section 151 of the Income Tax Act, 1961 (for short 'Act 1961'), notice da....

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.... 21509- 2023 and other connected matters), decided on 29.07.2024. 3. Learned counsel appearing for the respondent has also not disputed the same. 4. We have heard learned counsel for the parties and perused the file with their able assistance. 5. Co-ordinate Bench of this Court in Jatinder Singh Bhangu's case (supra) and Jasjit Singh's case (supra), allowed the writ petitions on t....

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....aceless assessment would be defeated if show cause notice under Section 148 is issued by Jurisdictional Assessing Officer. The respondents are heavily placing reliance upon office memorandum and letter issued by departmental authorities. It is axiomatic in tax jurisprudence that circulars, instructions and letters issued by Board or any other authority cannot override statutory provisions. The cir....