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2022 (12) TMI 1424

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..... ime was available only between 01.04.2021 and 30.06.2021 - Addition u/s 68 - HELD THAT:- Revenue, cannot but accept that insofar as the first aspect is concerned i.e., limitation, the same is covered by the judgment rendered by the coordinate bench in Suman Jeet Agarwal [ 2022 (9) TMI 1384 - DELHI HIGH COURT] For second aspect revenue says that there is no specific assertion in the counter-aff .....

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..... on reads as follows: a. Issue an appropriate Writ, direction or order quashing and setting aside the Order passed u/s 148A(d) and notice u/s 148 of the Income Tax Act, 1961 both dated 22.07.2022, issued by the Respondent No.1 and quash the reassessment proceedings initiated subsequent thereto and/or 2. The record shows, that the aforementioned impugned order dated 22.07.2022 passed unde .....

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..... was dispatched only on 14.07.2021, the proceedings are time barred. 5.1. In support of his plea, Mr Agarwal relies upon the judgment of a coordinate bench of this Court dated 27.09.2022 passed in a bunch of matters, one of which included W.P.(C) 10/2022, titled Suman Jeet Agarwal vs. Income Tax Officer. 6. Besides this, Mr Agarwal submits that the income that is chargeable to tax, which acc .....

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