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2019 (12) TMI 1542 - HC - Income TaxReopening of assessment u/s 147 - rejecting the objections filed by the petitioners against the reasons recorded as well as the assessment orders passed under subsection (3) of section 143 read with section 147 - Petitioner invited the attention of the court to the reasons recorded to point out that though the assessment has already been made in the hands of the association of persons, the Assessing Officer sought to reopen the assessment to make protective addition in the hands of the petitioners - as submitted impugned orders are passed in violation of the principles of natural justice and that the proceedings under section 148 of the Act were wholly without jurisdiction, therefore, these petitions under Article 226 of the Constitution of India against the assessment orders are maintainable - HELD THAT:- Having regard to the submissions advanced by the learned advocate for the petitioners, issue Notice, returnable on 13.01.2020. By way of adinterim relief, the operation of the assessment orders passed under section 143(3) read with section 147 as well as the impugned notices of demand issued under section 156 of the Act is hereby stayed.
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