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TMI Blog2022 (11) TMI 1023X X X X Extracts X X X X X X X X Extracts X X X X ..... s to surrender the PAN obtained as a Firm - HELD THAT:- We do not find any reasons to differ from the findings of the learned Single Judge. We however give liberty to the appellant to file statutory appeals. As the time limit for filing of the Statutory Appeals would have already expired, we direct the appellant to file statutory Appeal before the Appellate Commissioner u/s 246 A within a period of four weeks from the date of receipt of a copy of this order, along with required documents to putforth its submissions. If such appeals are filed within such time, the Appellate Commissioner shall pass necessary orders on merits and in accordance with law. All the issues are left open for being canvassed before the Appellate Commissioner. - W.A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rit Petitions in W.P.Nos.23388, 23385, 23376 and 23380 of 2022 before this Court and had challenged notices issued under Section 148 of the Income Tax Act, 1961 and the Assessment Orders passed thereon. 6. The case of the Appellant is that the reply was given to the aforesaid notices on 08.02.2022 wherein it was stated that the appellant had inadvertently applied for PAN as a Firm instead of 'Association of Person'. It is submitted that the appellant was in the process of surrendering the PAN and file afresh return with the revised PAN as an Association of Person would be filed and therefore could not earlier file returns of income in response to the notices. It is submitted that the Appellant is otherwise entitled to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... find any reasons to differ from the findings of the learned Single Judge. We however give liberty to the appellant to file statutory appeals. As the time limit for filing of the Statutory Appeals would have already expired, we direct the appellant to file statutory Appeal before the Appellate Commissioner under Section 246 A of the Income Tax Act, 1961 within a period of four weeks from the date of receipt of a copy of this order, along with required documents to putforth its submissions. If such appeals are filed within such time, the Appellate Commissioner shall pass necessary orders on merits and in accordance with law. All the issues are left open for being canvassed before the Appellate Commissioner. 11. This Writ Appeal stands dis ..... X X X X Extracts X X X X X X X X Extracts X X X X
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