TMI Blog2023 (2) TMI 1229X X X X Extracts X X X X X X X X Extracts X X X X ..... lkarni , Advocates For the Respondents : Y. V. Raviraj , Advocate JUDGMENT 1. Heard the learned counsel for the petitioners and the learned counsel for the respondents. 2. The petitioner in W. P. No. 202099 of 2022 is assailing the annexure D order of assessment under section 147 read with sections 144 and 144B of the Income-tax Act, 1961 and also the demand notice dated March 30, 2022 marked ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er the status of association of persons. After having realised this, the petitioner had applied for a permanent account number under the status of association of persons and the same was granted to the petitioner way back in the year 2011. 5. The contention of the petitioner is that after new permanent account number is assigned to the petitioner-society, the petitioner-society has submitted the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bankers, which maintain the account of the petitioner's society. However, it appears that there was a lapse on the part of the banker in updating the account of the petitioner by reflecting the new permanent account number. 8. Under these circumstances, it is the contention of the petitioner that the transaction though carried out under the new permanent account number, the transaction might ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mitted by the petitioner. 11. The learned counsel for the petitioner would also place reliance on the judgments of the High Court of Calcutta in M. A. T. No. 1943 of 2022 with I. A. No. CAN 1 of 2022, in the case of Shree Ramkirshna Sishu Tirtha v. ITO [2023] 457 ITR 729 (Cal), and in W. P. A. No. 17644 of 2022, in the case of Shakuntala Sales Incorporation v. Asst. CIT and would submit that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oner to substantiate its claim, the matter is remanded to the first respondent. For these reasons the impugned orders are set aside. 14. Since, the petitioner and the respondents are before this court, this court deems it appropriate that the petitioner shall appear before the first respondent on April 10, 2023 without awaiting notice from the first respondent. 15. With the above observations, t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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