2021 (9) TMI 703

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..... its. Nonetheless, in view of the fact that the main issues for consideration in such appeal are limited largely to the inclusion of unsecured loans and share capital as part of the total income of the assessee, are inclined to direct the expeditious disposal of the Appeal pending before the CIT (Appeals). Such appeal shall be decided after providing a reasonable opportunity to the petitioner, incl .....

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..... its that the aforesaid faceless Assessment Scheme envisages the issuance of a draft Assessment Order, which should be finalized only upon considering the objections of the petitioner. In the case at hand, the assessment was concluded without providing a reasonable opportunity to the petitioner. In specific, he points out that the Assessment Order included unsecured loans and share capital as incom .....

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..... expeditious disposal of the appeal at this juncture, but that the stay application could be directed to be disposed of expeditiously. 5.In view of the fact that the Assessment Order is appealable and such appeal has been filed by the petitioner, I am not inclined to consider the Writ Petition on merits. Nonetheless, in view of the fact that the main issues for consideration in such appeal are l .....

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