TMI Blog2022 (5) TMI 1453X X X X Extracts X X X X X X X X Extracts X X X X ..... he respective Assessees information and material relied upon by the Revenue, so that the Assesees can reply to the showcause notices within two weeks thereafter; The requirement of conducting any enquiry, if required, with the prior approval of specified authority under section 148A(a) is hereby dispensed with as a one-time measure vis-avis those notices which have been issued under section 148 of the unamended Act from 01.04.2021 till date, including those which have been quashed by the High Courts. Even otherwise as observed hereinabove holding any enquiry with the prior approval of specified authority is not mandatory but it is for the concerned Assessing Officers to hold any enquiry, if required; AO shall thereafter pass orders in terms of section 148A(d) in respect of each of the concerned Assessees; Thereafter after following the procedure as required under section 148A may issue notice under section 148 (as substituted); All defences which may be available to the assesses including those available under section 149 of the IT Act and all rights and contentions which may be available to the concerned Assessees and Revenue under the Finance Act, 2021 and in law shall c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2022 With R/SPECIAL CIVIL APPLICATION NO. 938 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 946 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 948 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 952 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 955 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 956 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 983 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1036 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1037 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1038 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1039 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1040 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1041 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1060 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1062 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1069 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1070 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1072 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1074 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1076 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1077 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1078 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1087 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1088 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th R/SPECIAL CIVIL APPLICATION NO. 1733 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1735 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1749 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1751 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1760 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1763 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1765 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1767 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1775 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1779 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1781 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1784 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1785 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1786 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1789 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1790 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1793 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1816 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1819 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1821 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1846 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1847 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1850 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1852 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th R/SPECIAL CIVIL APPLICATION NO. 2034 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2035 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2045 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2048 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2057 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2061 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2064 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2065 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2067 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2069 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2072 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2078 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2080 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2081 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2084 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2092 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2097 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2103 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2138 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2142 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2143 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2144 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2184 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2187 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th R/SPECIAL CIVIL APPLICATION NO. 2664 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2665 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2679 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2683 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2684 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2685 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2686 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2687 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2689 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2690 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2691 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2694 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2696 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2733 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2746 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2749 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2753 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2800 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2814 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2816 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2859 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2860 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2865 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2925 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th R/SPECIAL CIVIL APPLICATION NO. 3071 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3089 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3091 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3092 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3093 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3095 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3097 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3099 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3101 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3102 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3103 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3104 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3105 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3106 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3107 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3108 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3110 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3111 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3113 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3183 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3213 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3249 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3254 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3255 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th R/SPECIAL CIVIL APPLICATION NO. 3583 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3584 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3587 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3588 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3589 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3590 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3591 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3592 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3593 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3595 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3597 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3598 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3600 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3603 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3606 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3607 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3609 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3611 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3612 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3614 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3617 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3619 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3621 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3622 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th R/SPECIAL CIVIL APPLICATION NO. 3972 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3973 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3975 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3977 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3978 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3979 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3981 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3982 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3991 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3995 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3999 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4000 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4005 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4028 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4029 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4030 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4031 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4035 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4036 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4037 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4059 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4100 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4101 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4112 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th R/SPECIAL CIVIL APPLICATION NO. 4393 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4394 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4454 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4465 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4467 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4470 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4471 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4479 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4534 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4536 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4537 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4538 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4539 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4540 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4546 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4548 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4549 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4550 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4551 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4559 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4571 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4575 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4576 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4577 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th R/SPECIAL CIVIL APPLICATION NO. 4849 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4850 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4853 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4859 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4861 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4865 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4867 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4872 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4873 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4875 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4879 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4881 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4882 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4883 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4887 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4891 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4897 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4899 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4926 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4933 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4934 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4935 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4936 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4938 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th R/SPECIAL CIVIL APPLICATION NO. 5373 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5377 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5379 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5380 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5381 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5383 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5384 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5385 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5390 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5391 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5393 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5417 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5420 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5424 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5425 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5426 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5427 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5428 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5429 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5431 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5436 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5459 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5461 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5463 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th R/SPECIAL CIVIL APPLICATION NO. 5825 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5826 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5827 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5828 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5829 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5830 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5831 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5832 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5833 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5834 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5835 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5836 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5837 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5838 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5839 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5840 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5841 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5842 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5843 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5844 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5845 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5846 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5847 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5848 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th R/SPECIAL CIVIL APPLICATION NO. 6181 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6182 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6184 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6185 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6187 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6189 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6199 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6268 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6270 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6271 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6273 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6275 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6300 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6301 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6302 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6303 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6318 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6319 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6321 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6325 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6328 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6333 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6337 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6348 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th R/SPECIAL CIVIL APPLICATION NO. 7161 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7170 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7217 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7219 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7222 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7224 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7320 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7339 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7399 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7401 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7418 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7430 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7431 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7432 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7433 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7434 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7435 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7436 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7437 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7438 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7443 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7476 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7608 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7634 of 2022 Wi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IMIN R. DAVE, MR. PARV S. UPTA, MR. NIRAV C. THAKKAR, MR. S. P. MAJMUDAR, MR. ADITYA A. GUPTA, MR. MOHIT A. GUPTA AND MS. NUPUR D. SHAH, ADVOCATES FOR THE RESPONDENTS - REVENUE (INCOME TAX DEPARTMENT) IN THEIR RESPECTIVE WRIT APPLICATIONS : MR. DEVANG VYAS, ADDITIONAL SOLICITOR GENERAL OF INDIA APPEARING FOR THE UNION OF INDIA; MR. M. R. BHATT, SENIOR COUNSEL WITH MR. KARAN SANGHANI, LEARNED COUNSEL FOR M R BHATT CO.(5953) MR. VARUN K. PATEL, SENIOR STANDING COUNSEL; MS. KALPANA K. RAVAL, SENIOR STANDING COUNSEL WITH MR. NIKUNT K. RAVAL, STANDING COUNSEL NOTICE SERVED for the Respondent(s) No. 1 COMMON ORAL ORDER (PER : HONOURABLE MR. JUSTICE J.B.PARDIWALA) 1 We have heard Mr. Tushar Hemani, the learned Senior Counsel assisted by Ms. Vaibhavi Parikh; Mr. Tirth Nayak, Mr. Vijay Ranjan, Darshan Gandhi, Mr. Avinash Poddar, Mr. Manish J. Shah, Mr. Tej Shah, Mr. Darshan R. Patel, Mr. Dhinal A. Shah, Mr. S. N. Divatia, Ms. Archana Acharya, Mr. B. S. Soparkar, Mr. Mohit Balani, Mr. Priyam Shah, Ms. Kamya Manit Shah, Mr. Hiren J. Trivedi, Ms. Shrunjal T. Shah, Mr. Sudhir M. Mehta with Ms. Shailee S. Mehta, Mr. Hitendra D. Rajput, Ms. Divya Agrawal, Mr. Vijay H. Patel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the show-cause notices within two weeks thereafter; (ii) The requirement of conducting any enquiry, if required, with the prior approval of specified authority under section 148A(a) is hereby dispensed with as a one-time measure vis-a-vis those notices which have been issued under section 148 of the unamended Act from 01.04.2021 till date, including those which have been quashed by the High Courts. Even otherwise as observed hereinabove holding any enquiry with the prior approval of specified authority is not mandatory but it is for the concerned Assessing Officers to hold any enquiry, if required; (iii) The assessing officers shall thereafter pass orders in terms of section 148A(d) in respect of each of the concerned assessees; Thereafter after following the procedure as required under section 148A may issue notice under section 148 (as substituted); (iv) All defences which may be available to the assesses including those available under section 149 of the IT Act and all rights and contentions which may be available to the concerned assessees and Revenue under the Finance Act, 2021 and in law shall continue to be available. 11. The present order shall be applicable ..... X X X X Extracts X X X X X X X X Extracts X X X X
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