2022 (7) TMI 1642

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....This assessee's appeal for A.Y. 2006-07 is directed against the CIT(A)-6, Pune's order dated 22/03/2017 passed in case No. PN/CIT(A)-V/ITO Wd.8(1)/96/2014-15 involving proceeding u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961; in short "the Act". Heard both the parties. Case file perused. 2. We notice at the outset that the assessee has moved a petition dated 22.11.2019 seeking to raise ....

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....ords. There is hardly any dispute the assessee has already filed the clinching seized documents annexure R-3/ Bundle No.1 at page 17 of the paperbook. We therefore accept the assessee's above stated petition dated 22.11.2019 raising its additional substantial ground challenging validity of section 148/147 proceedings. 4. We now advert to foregoing legal issue. There is hardly any dispute that t....