2026 (8) TMI 1736

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....rection, calling for the records of the Petitioner's case and after going into the legality and propriety thereof, to quash and set aside the orders passed under section 148A(d) of the Act dated 06.04.2022 (for AY 2018-19) [Exhibit A2] and dated 21.03.2023 (for AY 2019-20) [Exhibit B2]; the notice issued under section 148 of the Act dated 06.04.2022 (for AY 2018-19) [Exhibit A3] and dated 26.03.2023 (for AY 2019-20) [Exhibit B4], the orders of re-assessment dated 08.12.2023 passed under section 147 read with section 144 of the Act [Exhibit C1 & D1], the notices of demand dated 08.12.2023 issued under section 156 of the Act [Exhibit C2 & D2]; for the relevant Assessment Years 2018-19 and 2019-20, respectively and the order dated 24.03.2026 r....

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.... iii) To refund the recovery made in excess of 5% of the impugned tax demand for the relevant Assessment Years. (c) That this Hon'ble Court be pleased to issue a writ of prohibition or a writ in the nature of prohibition or any other appropriate writ, order or direction under Article 226 of the Constitution of India prohibiting Respondents from taking any steps in furtherance of the re-assessment dated 08.12.2023 passed under section 147 read with section 144 of the Act [Exhibit C1 & D1], the notices of demand dated 08.12.2023 issued under section 156 of the Act [Exhibit C2 & D2]; for the relevant Assessment Years 2018-19 and 2019-20, respectively;" 2. Mr. Jain, the learned advocate appearing on behalf of the Petitioner fair....

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....t bear a "Document Identification Number" (DIN) and which is mandatory as held by certain decisions of this Court. If in fact what the Credit Society contends is true then we do not see any impediment in the 5th Respondent disposing of the Appeals in a time bound manner, especially taking into consideration the issues raised. 4. We accordingly direct that the 5th Respondent shall hear the Appeals of the Petitioner for A.Y. 2018-19 as well as A.Y. 2019-20 as expeditiously as possible, and in any event within a period of 12 weeks from the date of this order being brought to the attention of the 5th Respondent. 5. We are informed that some additional grounds have also been filed in the aforesaid Appeals. It is needless to clarify that al....