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2021 (4) TMI 1323

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..... s not adjudicated the issues, nor conducted any enquiry. First respondent conducted certain investigation and identified the immovable properties belong to the petitioner situate at Mumbai. All the files are now transferred to the authority at Chennai, who in turn issued notices on 14.12.2018 directing the petitioner to file the return of income for the assessment year 2011-12, in response to the notice issued under Section 148 of the IT Act, dated 28.03.2018. Though the second respondent has commenced the proceedings by issuing letters dated 14.12.2018, the petitioner is no way prejudiced and she has to avail an opportunity by submitting her objections and by following the procedures contemplated under the IT Act. The entire proceedi .....

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..... for the petitioner reiterated that on receipt of the notice from the first respondent, the petitioner sent a letter dated 26.04.2018 to the first respondent stating her Permanent Account Number and further stating that she is assessed by DCIT, Corporate Circle 4(2), Aaaykar Bhavan, M.G.Road, Nungambakkam, Chennai. Thus, a request is made to drop the proposal to assess/re-assess the income for the assessment year 2011-12. However, the second respondent, Assistant Commissioner of Income Tax, Corporate Circle-4(2), Chennai subsequently issued a notice under Section 143(2) read with Section 129 of the IT Act in proceedings dated 14.12.2018 and thereafter, issued another proceedings dated 14.12.2018 directing the petitioner to file return of in .....

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..... though improper, need not be set aside in view of the fact that the said proceedings were subsequently transferred to the Income Tax Authorities at Chennai. The first respondent has not adjudicated the issues, nor conducted any enquiry. However, the first respondent conducted certain investigation and identified the immovable properties belong to the petitioner situate at Mumbai. All the files are now transferred to the authority at Chennai, who in turn issued notices on 14.12.2018 directing the petitioner to file the return of income for the assessment year 2011-12, in response to the notice issued under Section 148 of the IT Act, dated 28.03.2018. Though the second respondent has commenced the proceedings by issuing letters dated 14.12.20 .....

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