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TMI Blog2023 (6) TMI 978X X X X Extracts X X X X X X X X Extracts X X X X ..... y that this was a case where no order u/s 143(3) had been passed - HELD THAT:- We find that in the order Rejecting petitioner s objections, has not given any reasons as to why he did not find any merit in the objections raised by the assessee. The assessee had also, in his objections, raised the issue of non application of mind by the PCIT while granting sanction u/s 151 - PCIT has simply endorsed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he reopening notice was issued after the expiry of four years of the assessment year but was candid to say that this was a case where no order under Section 143(3) of the Act had been passed. 3. Having heard Mr. Gandhi and considered the merits of the matter, we are not inclined to quash the notice dated 29th March 2019. 4. At the same time, we find that in the order dated 15th November 2019 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Jurisdictional Assessing Officer (JAO). 6. In our order dated 5th June 2023, paragraph 2 reads as under : 2. At Exhibit L to the affidavit in reply filed through one Dhirendra Jangir, affirmed on 2nd March 2020, is a request dated 29th March 2019 for approval to re-open the assessment under Section 147 of the Income Tax Act, 1961. In the application for approval, it is mentioned copies o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... directed respondents to provide has not been provided. 8. Since we are disposing the petition, we are not taking any action against respondents for not obeying the order passed by this Court on 5th June 2023. 9. Therefore, respondent no. 1 is directed to provide to petitioner the document that we have referred to in the order dated 5th June 2023 within two weeks from today. Within one week ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e provided to petitioner alongwith notice of personal hearing so that petitioner will be able to deal with those judgments/distinguish those judgments. 10. If the document mentioned in our order dated 5th June 2023 is not provided as recorded above, petitioner may apply to this Court for appropriate orders and in that case, the Court may even consider issuing notice of contempt on respondent no ..... X X X X Extracts X X X X X X X X Extracts X X X X
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