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2024 (9) TMI 1335

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..... 1.2023, to the extent prejudicial to the Petitioner as per pleadings, passed by the 1st Respondent for the AY 2013-14 bearing F. No. 31/264/Pr.CIT-PNJ/2023-24 enclosed as Annexure-A. (B) Quash by an appropriate writ or order in the nature of Certiorari or otherwise, the order under section 264 dated 20.11.2023, to the extent prejudicial to the Petitioner as per pleadings, passed by the 1st Respondent for the AY 2014-15 bearing F. No. 32/264/Pr.CIT-PNJ/2023-24 enclosed as Annexure-B. (C) Quash by an appropriate writ or order in the nature of Certiorari or otherwise, the order under section 264 dated 20.11.2023, to the extent prejudicial to the Petitioner as per pleadings, passed by the 1st Respondent for the AY 2015-16 bearing F. No. 3 .....

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..... .2023, the petitioner filed additional written submissions for A.Y.2013-14 to 2015-16, which have also not been considered fully and in the proper perspective, which would vitiate the impugned order; * Secondly, it is pointed out that in the impugned order, respondent No.1 refers to certain information said to have been procured from the Stock Exchange and Banks in relation to the petitioner, which had not been furnished to the petitioner for his explanation/say thereby violating the principles of natural justice and as such the impugned order deserves to be set-aside on this ground also and the matter to be remitted back to the respondents for reconsideration afresh in accordance with law. * Lastly, it is submitted that the petitione .....

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..... 23.11.2023 filed by the petitioner would also indicate that the same are relevant and necessary for the purpose of adjudication of the issues involved in the petition and since the same would have bearing/impact on the claim of the petitioner, the impugned order deserves to be set-aside. 7. A perusal of the impugned order will also indicate that reliance is placed by respondent No.1 on certain information said to have been procured/prescribed from the Stock Exchange and Banks. In this regard, the material on record would indicate that there is nothing to show that the said information had been furnished to the petitioner for the purpose of enabling him to have his say/explanation and as such impugned order is violative the principles of na .....

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