TMI Blog1991 (8) TMI 38X X X X Extracts X X X X X X X X Extracts X X X X ..... been filed under section 220(3) of the Income-tax Act, 1961, the Income-tax Officer was required to give an opportunity of hearing to the assessee before declining to grant the relief asked for. M/s. Kuku Rice Mills, petitioner No. 1, filed the return under the Income-tax Act for the assessment year 1988-89. The Income-tax Officer acting under section 143(3) of the Act raised additional demand ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... x Officer rejected those applications by passing the orders, annexures P-7 to P-9, which are being challenged in the present writ petition. The contention of counsel for the petitioner is that these impugned orders were passed without affording an opportunity of hearing to the petitioners and, secondly, these are not supported by reasons as these are not speaking orders. As far as the first poin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s were not maintainable as these were asking for a blanket stay of the recovery of the amount due and these applicants were not, in fact, praying for extension of time under section 220(3) of the Income-tax Act. It may be noticed that wrong provisions of the statute mentioned in the application or non-mentioning of the same will not be per se a ground to deny the relief asked for. The substance of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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