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2022 (11) TMI 1023 - MADRAS HIGH COURTReopening of assessment u/s 147 - petitioners are non-filers and there been also been no compliance to the various notices and questionnaires issued by the respondents - case of the Appellant is that the reply was given to the aforesaid notices wherein it was stated that the appellant had inadvertently applied for PAN as a “Firm “ instead of “'Association of Person' - Appellant submitted that the Appellant had taken steps to surrender the PAN obtained as a Firm - HELD THAT:- We do not find any reasons to differ from the findings of the learned Single Judge. We however give liberty to the appellant to file statutory appeals. As the time limit for filing of the Statutory Appeals would have already expired, we direct the appellant to file statutory Appeal before the Appellate Commissioner u/s 246 A within a period of four weeks from the date of receipt of a copy of this order, along with required documents to putforth its submissions. If such appeals are filed within such time, the Appellate Commissioner shall pass necessary orders on merits and in accordance with law. All the issues are left open for being canvassed before the Appellate Commissioner.
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