2024 (3) TMI 1569

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....x<br>THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE N.TUKARAMJI For the Petitioner : Sri M. Naga Deepak For the Respondents : Sri J.V. Prasad, (Sc For Income Tax) ORDER (per Hon&#39;ble Sri Justice P.SAM KOSHY) Heard Mr.M.Naga Deepak, learned counsel for the petitioner and Mr. J.V. Prasad, learned Senior Standing Counsel for the Income Tax Department for respo....

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.... One of the contentions that the petitioner has raised in the present Writ Petition is that under the amended provisions of the Act which came into effect from 01.04.2021, the respondents, while proceeding under Section 148 of the Act, were required to issue notice under Section 148A and provide an opportunity of hearing to the assessee. As per the amended provision of law, the proceedings to be d....

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....e learned counsel for the respondent-Department is concerned, this Bench, while disposing of said batch of writ petitions, had taken note of the same at paragraph Nos.37 & 38 which are reproduced herein under: "37. The preliminary objection raised by the petitioner is sustained and all these writ petitions stands allowed on this very jurisdictional issue. Since the impugned notices and or....