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2019 (3) TMI 1561 - GUJARAT HIGH COURTStay on recovery of demand - deposit 20% of the demand within three days of the date of receipt of the letter - no search was initiated under section 132 nor were the books of account or other documents or any assets requisitioned under section 132A and hence, no assessment could have been made under section 153A - HELD THAT:- Review of the order of the Assessing Officer, has not examined the submissions advanced on behalf of the assessee on the specious plea that none of the pleas are covered by the guidelines given by the CBDT in its revised Instruction No.1914 relating to stay on recovery of demand. As further submitted that the Principal Commissioner of Incometax has passed the impugned order on 11.03.2019, which came to be furnished to the petitioner only on 22.03.2019 and thereafter, without giving any time to the petitioner to challenge the impugned order, the bank account of the petitioner has been attached on 25.03.2019. Having regard to the submissions advanced by the learned advocate for the petitioner, issue Notice, returnable on 01.04.2019.
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