2023 (11) TMI 1255

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..... For the Appellant : Mr. Sanjeev Singhal For the Respondent : Mr. Shantanu Sharma with Ms. Bhavna Laddha and Mr. Anurag Mathur ORDER Learned counsel for the appellant presses this appeal on the proposed substantial questions of law which reads as under:- "i) Whether in facts and in the circumstances of the case Learned Income Tax Appellate Tribunal was justified in upholding the action of A .....

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..... Successors to Office & 4 respondent(s) reported in SCA/5295/2010 decided on 13.07.2010. From the record pleadings made by the appellant, it does not appear that the issue of limitation has been raised on a factual foundation that though notice under Section 148 of Income Tax Act, 1961 bears the date 31.03.2017, it was not issued on that date but it was put in the course of dispatch after that da .....

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