TMI Blog2023 (3) TMI 1408X X X X Extracts X X X X X X X X Extracts X X X X ..... ce was issued to the petitioner on 04.02.2022, one year has already passed whereafter the present petition came to be filed. In absence of any plausable explanation as to delay and also in face of statutory remedy of objection available to the petitioner, which objection has also been filed, we do not consider it a fit case to offer any interference in exercise of extraordinary jurisdiction of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... evenue. 2. Challenge has been raised to the notice dated 04.02.2022 issued by the Assessing Authority of the petitioner under Section 153-C of the Income Tax Act, 1948 (hereinafter referred to as the 'Act') for A.Y. 2015-16. 3. Contention of learned counsel for the petitioner is, in the present case, the petitioner was not subjected to any search proceeding under Section 132 of the A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rned counsel for the revenue would contend, the provision of Section 153-C(3) of the Act would not apply to the case of the petitioner inasmuch as that provision applies to the person searched which in the present case is the Saloni Group. Alternatively, that plea is also open to the petitioner to raise before the Assessing Authority. 6. Then, it has been stated, the loose documents would const ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in exercise of extraordinary jurisdiction of this Court under Article 226 of the Constitution of India. 10. Without adjudicating the merits of the objection raised by learned counsel for the petitioner and leaving it open to the petitioner to press those objections first before the Assessing Authority, whereafter the matter may be entertained on merits, present writ petition is disposed of wit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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