2026 (3) TMI 576

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....NIL DUTT YADAV For the Petitioner: (By Sri. Atul K Alur., Advocate). For the Respondents: (By Sri. Shanthi Bhushan H., DSGI For R1; Sri. Aravind V. Chavan, Advocate For R2). ORAL ORDER The petitioner has called in question the validity of the order of adjudication which is the Order in Original at Annexure-D passed by respondent No. 3 for the period 2016-17. 2. Learned counsel for t....

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....ed that mechanical issue of show-cause notice is merely on the basis of declaration in the income tax returns was in fact noticed by this Court in W.P. No. 11154/2023 and accordingly, it is requested that the Order in Original be set aside and matter be remitted to the stage of reply to show-cause notice. 5. Perused the order dated 03.07.2024 passed in W.P. No. 11154/2023 and connected petition....

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.... 5) Whether claims are barred by limitation in terms of the law laid down by the Apex Court? 11. It is also clarified that disposal of present petitions must not be construed as having adjudicated any of the contentions including jurisdiction. All contentions of both sides on merits are kept open. 12. Needless to state, upon conclusion of proceedings, if any of the petitio....

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....ssion made above, the Orders-in-Original stand set aside and the matters are relegated to the Officers to be designated to be reconsidered from the stage of show-cause notice. Accordingly, such of the petitions at Sl. No. 1 to 35 in Column No.2 of the table relating to challenge to Orders-in-Original are disposed off. The petitioners who are now relegated before the authorities c....