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TMI Blog2025 (5) TMI 447X X X X Extracts X X X X X X X X Extracts X X X X ..... AND HON'BLE MR. JUSTICE TEJAS KARIA For the Petitioner Through: Mr. Gagan Kumar, Ms. Puja Jakhar, Mr. Gagandeep, Advocates. For the Respondents Through: Mr. Shlok Chandra, Sr. Standing Counsel with Ms. Naincy Jain, JSC; Ms. Madhavi Shukla, JSC and Mr. Ujjwal Jain, Advocate. VIBHU BAKHRU, J. (ORAL) 1. The Petitioner has filed the present petition, inter alia, impugning an order dated 20. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n 16.04.2025 and this court had passed the following order: "W.P.(C) 4773/2025 & CMAPPL. 21987/2025(Stay) CM APPL. 21989/2025(Addl. documents) W.P.(C) 4789/2025 & CM APPL. 22031/2025(Stay) CM APPL. 22033/2025(Addl. documents) 3. The petitioner has filed the present petitions, inter alia, impugning the order(s) dated 20.03.2025 [impugned orders] passed under Section 147 of the Income T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ite to examine whether the impugned orders are passed wholly without any jurisdiction. 7. Mr Chandra, learned counsel appearing for the Revenue submits that an order under Section 127 of the Act has been passed. However, he requires to take confirm instructions in this regard. Clearly, if an order under Section 127 of the Act has been passed, the impugned orders cannot be stated to be wholly wit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alid on the ground that it assumes that the Petitioner is an assessee located in Delhi; and second, that no notice was issued to the Petitioner before passing the said order. Clearly, none of these grounds find mention in the present petition as according to the Petitioner, no such order existed. 5. Insofar as other contentions are concerned, considering that the Petitioner is also challenging th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rify that all rights and contentions of the parties are reserved and the Petitioner would not be precluded from assailing the impugned order, inter alia, on the grounds as urged in the present petition. Additionally, we clarify that the Petitioner is also at liberty to avail other remedies in respect of the order dated 17.12.2024 passed under Section 127 of the Act. 9. The petition is disposed of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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