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2023 (6) TMI 824 - BOMBAY HIGH COURTReopening of assessment u/s 148A - service upon the AO - petitioner failed to file any objections to the notice even though the opportunity and time of two weeks were granted to the petitioner to file objections - HELD THAT:- The period from the date of the impugned order dated 29/07/2022 till today will stand excluded or in any case; the timeline will stand proportionately extended. We clarify that we have not examined the merits of the matter because the same has to be examined by the AO. Needless to add, all contentions of all parties, including the defences available to the Assessee u/s 149 of the Income Tax Act and all rights and contentions that may be available to the Assessee and the Revenue in law. The rule is accordingly made absolute in terms of prayer clause ‘b’ of this petition which reads as follows with liberty to the AO to make fresh order after considering petitioner’s objections/response.
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