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2023 (1) TMI 1269

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..... C. ORDER 1. Heard Sri Suyash Agarwal, learned counsel for the petitioner and Sri Ashish Agrawal, learned counsel appearing for respondents No.1 and 2. 2. Proceedings for reassessment under Section 148 of the Income Tax Act was initiated by the Income Tax Department by invoking relevant provisions and issuing notice and an assessment order was passed on 27.3.2015. The dispute is for the assessme .....

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..... s invited the attention of the Court to the findings recorded by the Assessing Authority wherein categorical findings has been recorded by the Assessing Authority that the notice was served through speed post as well as by affixture but the Assessee did not turn up. He invited the attention of the Court to paras 3.4, 3.5 and 3.6 of the assessment order, which is extracted hereasunder : "3.4 Agai .....

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..... ur on 13/03/2015 by the Inspector, assessee's letter dated 18/03/2015 was received in this office on 20/03/2015 intimating that assessee has received a call from Shankar Sadan, Gorakpur, (a proof enough to establish that persons of both places are well acquainted) and requesting for another date which could not be allowed at this juncture when the case is to be barred by limitation on 31/03/20 .....

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..... fact that the notice issued under section 148 of Income Tax Act was served upon the Assessee and categorical findings has been recorded and the assessment order was passed. 7. As there was no challenge to the findings recorded by the Assessing Authority, the Revisional Authority has not ventured into the arena and has dismissed the revision of the Assessee. The argument raised by the petitioner h .....

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