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2022 (10) TMI 770

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..... anchanda, Advocates. Respondents Through: Mr. Abhishek Maratha, Sr. Standing Counsel for Revenue. J U D G M E N T MANMEET PRITAM SINGH ARORA, J (ORAL): CM APPL. 6591/2022 Exemption allowed, subject to all just exceptions. Accordingly, this application is disposed of. W.P.(C) 2295/2022, CM APPLs. 6603/2022, 9429/2022 & 9430/2022 1. Present petition has been filed impugning notices all dated .....

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..... ments and books found and seized during the course of search on the parents relates to the petitioner herein. Thereafter, on 22nd December, 2020, respondent no.2, the Assessing Officer of the petitioner, issued the impugned notices under Section 153C of the Act for the AY 2011-12 to 2017-18 and impugned notice dated 23rd December, 2020, under Section 143(2) of the Act for the AY 2017-18. 3. It is .....

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..... ficer ('AO'). It is further stated that the directions issued by the CIT(A) was only with respect to AY 2016-17 and 2017-18, the seized material relates to AY 2016-17 and 2017-18 and therefore, the notices issued for AY 2011-12 to 2015-16 are without any basis. It is also stated that since the petitioner was a minor during AY 2011-12 to 2014-15, no notice could have been issued for the said assess .....

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..... Y 2017-18 under Section 153C of the Act. The said assessment orders are not a subject matter of the present writ petition. The challenge to the assessment orders would necessarily require examination of factual controversy. The petitioner has the remedy of filing an appeal against the said assessment orders. In this respect the judgment of Supreme Court in Commissioner of Income Tax vs. Chhabil Da .....

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