TMI Blog2019 (12) TMI 580X X X X Extracts X X X X X X X X Extracts X X X X ..... ntenable. So far as the satisfaction of the concerned Ao and the Commissioner, Income Tax is concerned, a perusal of the pages Nos.65 to 69 available on record clearly suggests that both the authorities have applied their mind objectively and to the fullest extent required under the law. No other argument was advanced by the learned counsel for the petitioner. This Court does not find the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the present notice are exactly identical and there is no new material with the respondents to initiate fresh proceedings under Section 148 of the Act of 1961, particularly when the proceedings in furtherance of the earlier notice have already culminated into an assessment order dated 18.12.2018. The basic premise for challenging the re-assessment proceedings is, that a fresh notice ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r Section 147/143(3) of the Act of 1961. Indisputably, the notice, which has been challenged in the present writ petition is for the Assessment Year 2013-14. The reasons mentioned and the satisfaction arrived at by the Commissioner is in the same phraseology, however, the same by itself does not render the proceedings to be void or without jurisdiction. A set of paper seized/recove ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , Income Tax is concerned, a perusal of the pages Nos.65 to 69 available on record clearly suggests that both the authorities have applied their mind objectively and to the fullest extent required under the law. No other argument was advanced by the learned counsel for the petitioner. This Court does not find the impugned notice to be void or without jurisdiction in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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