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2023 (8) TMI 1283

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..... learned Senior Standing Counsel takes notice on behalf of the respondent. 2. The petitioner is aggrieved by the impugned Assessment Order passed by the respondent under Section 148A(d) of the Income Tax Act, 1961. 3. By the impugned order dated 14.04.2023, the respondent has passed the following order:- "4. After considering the information available on record and the reply of the assessee, t .....

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..... third proviso of Section 149(1) of the IT Act, the time available for issue of notice under 148 of the IT Act is up to 15.04.2023. 7. This order is passed with the prior approval of the Principal Chief Commissioner of Income Tax, Chennai." 4. The petitioner had not filed the returns in time. Instead, the petitioner had filed a manual return on 31.03.2018 wherein, the petitioner declared that t .....

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..... s of the information/enquiry conducted on which reliance is being placed, along with supporting documents, are enclosed with this notice. 2. You are required to show-cause as to why, in view of the details contained in enclosures mentioned in point number 1 above, a notice section 148 of the Income Tax Act, 1961 should not be issued. 3. You may submit your reply to this notice, along with supp .....

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..... ax Act, as amended with effect from 01.04.2021, the petitioner has also replied on 16th of March 2023, wherein, the petitioner has stated that the total deposit in cash that was made by the petitioner was only for INR 21,65,000 as against INR 65,02,546 between 01-04-2015 and 31-03- 2016. 8. It is therefore submitted that there is no material available with the respondent to pass the impugned orde .....

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