2020 (6) TMI 436

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..... he Petitioner : Mr. Sanjay Jain, ASG Mr. S.K. Singhania, Adv. Ms. Gargi Khanna, Adv. Mrs. Anil Katiyar, AOR For the Respondent : Mr. Arvind Datar, Sr. Adv. Mr. Mahesh Agarwal, Adv. Mr. M.S. Ananth, Adv. Mr. Anshuman Srivastava, Adv. Mr. E.C. Agrawala, AOR ORDER UPON hearing the counsel the Court made the following Delay condoned. In the present matter, the assessment order was passed on 30 .....

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..... and the Petitioner had responded to the same by its letters dated 10 December 2017 and 21 December 2017 justifying its stand. The non-rejection of the explanation in the Assessment Order would amount to the Assessing Officer accepting the view of the assessee, thus taking a view/forming an opinion. Therefore, in these circumstances, the reasons in support of the impugned notice proceed on a mere .....

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