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2021 (4) TMI 1099

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..... ORDER Heard Mr.J.Harikrishna, learned counsel for the petitioner and Mrs.Hema Muralikrishnan, learned Senior Standing Counsel for the revenue. 2. The challenge in this matter is to an order of assessment passed in terms of the provisions of the Income Tax Act, 1961 (in short 'Act') dated 16.12.2019 for Assessment Year (A.Y.) 2017-18. The main ground agitated is violation of principles of .....

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..... J.Harikrishna, learned counsel for the petitioner and Mrs.Hema Muralikrishnan, learned Senior Standing Counsel for the respondent. 2. This is a case where the petitioner has not filed a return of income and the proposal for assessment refers to certain bank transactions involving specified bank notes during the demonetization period which are proposed to be brought to tax. No doubt, the petition .....

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..... for a subsequent personal hearing. Thus the show cause notice sent by e-mail would have been instantly received by the petitioner and a hearing has been conducted in pursuance thereof. 4. This submission assumes that reply dated 12.12.2019 and personal hearing conducted on the same day is pursuant to show cause notice dated 11.12.2019. 5. The Records of assessment must reveal this position and .....

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..... n 12.12.2019. 8. The benefit of doubt, in the above circumstances, should be extended to the petitioner. It is also admitted that the show cause notice has been received by the petitioner on the date of hearing and beyond the time of hearing. The impugned order is also passed on the same date of hearing proposed in the show cause notice, i.e., 16.12.2019. 9. In the light of the aforesaid discuss .....

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