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2024 (4) TMI 839

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..... hence Petitioner was unable to file a reply - as argued that if Petitioner is given an opportunity to reply to the notice u/s 148A(b) she is confident that she will be able to satisfy the AO that the notice u/s 148A(b) will have to be dropped - HELD THAT:- Considering the facts and circumstances of the case that Petitioner is a Public Trust and running a school, in our view, Petitioner should be .....

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..... h 2022 passed under Section 148A(d) of the Income Tax Act, 1961 ( the Act ) and the consequential notice dated 25th March 2022 under Section 148 of the Act issued by Respondent No. 1. Though various grounds have been raised in the petition, in the impugned order dated 23rd March 2022, it is observed that Petitioner did not reply to the notice dated 11th March 2022 issued under Section 148A(b) of t .....

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..... me, considering the facts and circumstances of the case that Petitioner is a Public Trust and running a school, in our view, Petitioner should be given an opportunity to reply to the notice dated 11th March 2022. 3. In the circumstances, without expressing any opinion on the merits of the matter, we hereby quash and set aside the impugned order dated 23rd March 2022 passed under Section 148A(d) of .....

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