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TMI Blog2021 (4) TMI 1225X X X X Extracts X X X X X X X X Extracts X X X X ..... n, that there is a violation of the provisions of the Act. Assessing Officer was perhaps required to pass, in the first instance, an order under Section 144 C (1) of the Act, which would have enabled the petitioner to file, if so aggrieved, its objections with the Dispute Resolution Panel. Mr. Zoheb Hossain, who appears on advance notice, contends that for the moment, he does not have instru ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... behalf of the petitioner, says that the impugned order dated 26.03.2021 is not only contrary to the provisions of the Income Tax Act, 1961 [in short the Act ], but has also been passed in the breach of the principles of natural justice. 2. According to him, a perusal of the impugned order would show that, based on the input of the Transfer Pricing Officer, a final assessment order was passed, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enalty proceedings u/s. 270A are initiated. Issued notice u/s 274 r.w.s. 270A of the IT Act, 1961 for underreporting of income as mentioned at Para 5 above ... 4. In support of this plea, he has also referred to pages 67 to 69 of the electronic file, wherein the notice of demand, penalty notice and the screenshot of the revenue's portal have been appended. 5. Prima facie, we are of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Hossain will revert with instructions. In case, Mr. Hossain receives instructions to resist the petition, he will file a counter-affidavit before the next date of hearing. 11. In the interregnum, there shall be a stay on the operation of the impugned order dated 26.03.2021 pertaining to AY 2017-2018. Furthermore, there shall also be a stay on the demand notice dated 26.03.2021 concerning AY 20 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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