9911796707
TMI Blog2021 (9) TMI 1480X X X X Extracts X X X X X X X X Extracts X X X X ..... ainst the draft assessment order, the assessee has approached the Dispute Resolution Panel (DRP), the writ petitions were disposed of by permitting the respondents/writ petitioner to pursue the statutory remedy as opted by it and accordingly, the writ petition was closed. In such circumstances, the Appellant cannot be aggrieved over the said order, and the Learned Writ Court did not apply the c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tioner would be entitled to canvass all legal and factual issues before the Income Tax Appellate Tribunal, before which the appeal is now pending, including the point relating to limitation. Accordingly, the writ appeal is disposed of. - W.A. No. 2051 of 2021 and C.M.P. Nos. 11989 and 13031 of 2021 - - - Dated:- 16-9-2021 - Honourable Mr. Justice T.S. Sivagnanam And The Honourable Mr. Justi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dealt with the case in paragraph No.32 of the impugned order. Wherein there are two writ petitions, which have been referred to, one of which has been filed by the respondent herein. 3. The Learned Writ Court noting that as against the draft assessment order, the assessee has approached the Dispute Resolution Panel (DRP), the writ petitions were disposed of by permitting the respondents/writ pe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ner. This issue is obvious, because, the writ petition filed by the respondent-writ petitioner was not adjudicated on merits and was closed, as the respondent chose to avail the alternate remedy provided under the Act by approaching the DRP. It is made clear that the respondent-writ petitioner would be entitled to canvass all legal and factual issues before the Income Tax Appellate Tribunal, befor ..... X X X X Extracts X X X X X X X X Extracts X X X X
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