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2023 (6) TMI 672

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..... his stand was not taken in time. The writ petition is disposed of, with a direction that before the Assessing Officer proceeds to pass an assessment order, he would verify the assertion made by the petitioner/assessee which is recorded in the reply, and in this context, also accord personal hearing to the petitioner/assessee and/or his authorised representative. - W.P.(C) 6054/2023 - - - Date .....

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..... lenge is also laid to the notice dated 29.05.2022 issued under Section 148A(b) of the Act. 3.2 In addition thereto, there is also a challenge laid to Instruction No. 1 of 2022 dated 11.05.2022, issued by the CBDT. 4. Ms Ananya Kapoor, learned counsel, who appears on behalf of petitioner/assessee, fairly concedes that no response was submitted by the petitioner/assessee to the aforementioned .....

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..... nder Section 148A(d), would show that the petitioner/assessee has taken the stand that he did not enter into any transaction with Dayanand Singh, as alleged by the respondent/revenue, or at all. Ms Kapoor submits that if the amount alleged to have been transacted with Dayanand Singh, i.e., Rs. 33,81,000/- is taken out of the equation, the alleged escaped income would be below Rs. 50 lakhs. 5. U .....

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