TMI Blog2021 (5) TMI 490X X X X Extracts X X X X X X X X Extracts X X X X ..... 11.2019 and therefore, an opportunity should have been given to the petitioner to inspect the documents - HELD THAT:- In view of the same, the respondent is directed to dispose of the representation of the petitioner's son, dated 06.11.2019, on merits and in accordance with law, by affording an opportunity of hearing to the petitioner, within a period of six weeks from the date of receipt of a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ndividual assessee on the file of the respondent holding PAN No.AAZPU0395D under the Income Tax Act, 1961. According to the petitioner, the returns were not filed by her son under Section 139 of the Income Tax Act, 1961, for the assessment year 2012-13 and therefore, the respondent received interim report regarding the enquiry conducted by the Assistant Director of Income Tax (Investigation), Unit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and the same are pending consideration. In the said appeals, certain grounds have been raised regarding the validity of the assumption of jurisdiction under Section 147 / 148 of the Income Tax Act, 1961. (iv) Further, the petitioner's son had also challenged the validity of re-opening of the assessments on the ground that there is no independent application of mind and therefore, he had sen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rned counsel appearing for the petitioner would state that no opportunity was given either to her son or the petitioner, to inspect the records and take copies of the documents, by considering the representation of the petitioner's son dated 06.11.2019 and therefore, an opportunity should have been given to the petitioner to inspect the documents. 4. Heard the learned Special Government Ple ..... X X X X Extracts X X X X X X X X Extracts X X X X
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