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TMI Blog2022 (6) TMI 809X X X X Extracts X X X X X X X X Extracts X X X X ..... ) RESPONDENTS (BY SHRI SANJAY LAL, ADVOCATE) ORDER PER : JUSTICE SHEEL NAGU : The petitions registered as W.P. No.11845/2021, W.P. No.11840/2021, W.P. No.11842/2021, W.P. No.11843/2021, W.P. No. 11844/2021, W.P. No.11853/2021, W.P. No.11863/2021, W.P. No.11936/2021 & W.P. No.12660/2021 involve common question of law based on similar factual matrix and, therefore, are being decided by the present common order. The factual matrix of W.P. No.11845/2021 is considered for disposal of all the connected matters. 2. Learned counsel for rival parties are heard on the question of admission so also on final disposal. 3. Learned counsel for petitioner, Shri Prashant Shukla while assailing the impugned assessment order dated 21.04.2021 passed by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ears. In response, the petitioner submitted letter dated 04.01.2021 stating that the return filed u/S 139 of the IT Act for the respective assessment years may be treated as return of income filed u/S 153A of the IT Act for the six assessment years under scanner. The Revenue further submits that based on the information so provided by the owner, the same was assessed and the objections raised by the petitioner were found to be untenable and thus rejected on 18.02.2020. The Revenue further submits that while doing so, the Assessing Officer took into account the pending Writ petition in the Allahabad High Court assailing the order passed u/S 127 of the IT Act for centralization of a case of assessee with the Central Circle, Jabalpur which cam ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f opportunity of being heard to the petitioner. 5. Learned counsel for petitioner has though vehemently argued qua issue of non affording of opportunity but has not been able to point out a single statutory provision relating to affording of opportunity contained in any of the relevant provisions of the IT Act which according to the the petitioner has been breached. 6. A bare perusal of the impugned assessment order reveals that notice was issued to the petitioner during the conduction of search and seizure operations which were duly responded to by the petitioner by contending that the returns already filed by him be treated as returns for the purpose of search and seizure proceedings. More so, the said return of computation of income an ..... X X X X Extracts X X X X X X X X Extracts X X X X
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