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2020 (10) TMI 803

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..... t the Assessee is bound to cooperate and present himself before the concerned competent Authority, whenever he is summoned for any enquiry in the matter. Of course, it is expected that the concerned Authority also was expected to comply with the directions of the learned Single Judge and issue the show cause notice within a period of two weeks from the date of the order of the learned Single Judge viz., 06.01.2020 - However, since that could not be done for some reasons beyond the control of either of the parties and a fresh attachment order has been made on 28.03.2020, the concerned show cause notice should be issued now by the competent Revenue Authority latest within a period of three months from today. This will be conditional upon th .....

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..... ceedings being pending with the concerned Authority and not concluded so far. 2.After the order of the learned Single Judge, various overriding circumstances, including the spread of COVID-19, have happened worldwide including India, and therefore, it seems that these proceedings could not be concluded and even the expected show cause notice, which was to be issued in pursuance of the directions of the learned Singe Judge, could not be issued within the period of two weeks, as directed in the order dated 06.01.2020. 3.The learned Additional Solicitor General, appearing on behalf of the Revenue, submitted that the Assessee is not cooperating in the matter and has not presented himself for verification of certain preliminary materials c .....

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..... e parties and a fresh attachment order has been made on 28.03.2020, we are of the opinion that the concerned show cause notice should be issued now by the competent Revenue Authority latest within a period of three months from today. This will be conditional upon the Assessee fully cooperating in the matter. 6.The learned counsel for the first respondent/Assessee has assured the Court that the Assessee is always cooperating in the matter and has further undertaken to cooperate with the said Authority in the proceedings pending before the concerned authority. 7.Accordingly, we direct the first respondent / Assessee to appear before the concerned Authority in the first instance on 02.11.2020 and present himself with the relevant mat .....

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