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2018 (3) TMI 673

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..... thout examining the other contention raised on behalf of the Petitioner, in the present facts, it would be in the interest of justice that the impugned order dated 20.11.2017 disposing of the objections is set aside and the Petitioner is given an opportunity to file his objections afresh in the context of the material now available (relied upon by the Revenue). As the Petitioner, states that they .....

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..... t the stage of admission. 2. This Petition under Article 226 of the Constitution of India challenges the notice dated 31.3.2017 issued under Section 148 of the Income-Tax Act, 1961 (The 'Act') and the order dated 20.11.2017 disposing of the Petitioner's objections to the reasons in support of the impugned notice. The impugned notice seeks to reopen the assessment for the Assessment .....

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..... r relevant portions of such report should be enclosed alongwith the reasons. It is now in the affidavit-in-reply that the Revenue seeks to rely upon the report received from the Assistant Director of Income-Tax (Investigation) as it is annexed thereto. The Petitioner did not have an opportunity to present his objections in the context of the communication received by the Assessing Officer fro .....

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..... xt of the material now available (relied upon by the Revenue). Mr. Khurana, the learned counsel for the Petitioner, states that they would file their fresh objections within two weeks from today. The Assessing Officer would pass fresh order after considering the fresh objections filed by the Petitioner, within a period of four weeks after filing of the objections. Thereafter the Assessing Offic .....

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