2022 (2) TMI 1034

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..... r opportunity has not been provided to put up their submissions and defence and the order goes beyond the contents of the show cause notice. Learned counsel also relied upon the judgment delivered by Delhi High Court in the case of Sanjay Aggarwal Vs. National Faceless Assessment Centre, Delhi [ 2021 (6) TMI 336 - DELHI HIGH COURT ] to submit that the provision contained under Section 144-B 7 (v .....

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..... der Section 144-B of Income Tax, 1961 can be examined by the High Court without insisting upon filing of an appeal which is not only cumbersome but also virtually is in the same prospective as there is no personal hearing provided. Learned counsel submits that the petitioner moved an application in terms of Section 144-B 7(vii) seeking an opportunity of personal hearing which has been denied. L .....

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