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2017 (10) TMI 694

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..... more opportunity to go before the Assessing Officer and put forth their objections as the pattern of assessment is identical to all the assessment orders and the revision of assessment itself is based upon report of the Enforcement Wing - the petitioner is to treat the impugned orders as show cause notices and submit their objections within a period of 15 days from the date of receipt of a copy o .....

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..... postal endorsement left . Consequently, the petitioner did not know about the assessment being completed and the impugned orders of assessment being passed. Since they had no notice of the proceedings and after having come to know that the impugned assessment orders have been passed, the petitioner was unable to obtain a copy of the orders and therefore, they had approached this Court in W.P.No.67 .....

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..... t the impugned assessment orders have been solely based upon the report submitted by the Enforcement officials vide report dated 12.06.2015, wherein there is a positive direction to the Assessing Officer to implement the proposal and thus, there is no independent application of mind on the part of the Assessing Officer. 5. Thirdly, it is contended that the reason for disallowance of the claim b .....

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..... orders as show cause notices and submit their objections within a period of 15 days from the date of receipt of a copy of this order. On receipt of the objections, the respondent shall afford an opportunity of personal hearing and redo the assessment in accordance with law. Till such time, no coercive action shall be initiated against the petitioner for recovery of the tax and penalty as quantifi .....

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