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2020 (8) TMI 326

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..... Advocate with Mr. Himanshu Sethi, Advocate. Respondents Through: Mr. Zoheb Hussain, Senior Standing Counsel for respondent Nos. 1-3. Mr. Sanjeev Sabharwal, Sr. Panel Counsel for respondent No. 4. JUDGMENT MANMOHAN, J: (Oral) 1. The petition has been heard by way of video conferencing. 2. Present writ petition has been filed seeking refund of INR 18,90,35,522/- (Rupees Eighteen Crores Ninety L .....

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..... submits that the reasons as recorded by the Assessing Officer and approved by the PCIT are nothing but CASS reasons as recorded in notice under Section 143(2) of the Act. He also submits that respondent no.1 could not have styled petitioner's letter dated 15th May, 2020 as a revision petition and, in any event, could not have entertained a revision petition under Section 264 against its own order. .....

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..... hrough email." 5. Today Mr.Zoheb Hossain, Advocate appearing for the respondents - Revenue, on instructions states that the respondents, without prejudice to their rights and contentions and without admitting to any illegality are willing to re-consider as to whether Section 241A of the Act is attracted to the present case and pass a fresh order in accordance with the judgments passed by this Cou .....

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..... sioner of Income Tax to the withholding of the refund amount, or any part thereof, should be completed within six weeks from today, failing which, we direct that without awaiting any further orders, the respondents shall transmit the amount of refund determined under section 143 (1) of the Act along with interest to the petitioner. In the eventuality of the respondents recording any reasons for wi .....

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