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2023 (7) TMI 29

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..... e matter. Given this position, AO had put the petitioner on an extremely tight leash. AO expected the petitioner to gather information for six AYs within two days, which by any yardstick was not a practical timeframe. This is especially so, as the AO, while issuing notice under Section 153C of the Act, had granted 30 days to the petitioner to file the return of income concerning the AYs in issue. Thus, for the foregoing reasons, we are inclined to set aside the impugned assessment orders. - W.P.(C) 6818/2023 & CM Nos. 26617-18/2023 - - - Dated:- 19-5-2023 - W.P.(C) 6827/2023 CM Nos.26747-48/2023 W.P.(C) 6828/2023 CM Nos.26749-50/2023 W.P.(C) 6830/2023 CM Nos.26756-57/2023 W.P.(C) 6832/2023 CM Nos.26761-62/2023 W.P.(C .....

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..... aptioned writ petitions, based on the record presently available to the Court. 3.1 Thus, with the consent of learned counsel for the parties, these writ petitions are taken up for hearing and final disposal at this stage itself. 4. These writ petitions concern Assessment Year (AY) 2017-18 [W.P.(C) No.6818/2023]; AY 2013-14 [W.P.(C)No.6827/2023]; AY 2016-17 [W.P.(C)No.6828/2023]; AY 2015-16 [W.P.(C)No.6830/2023]; AY 2018-19 [W.P.(C)No.6832/2023]; AY 2019-20 [W.P.(C)No.6837/2023] and AY 2014-15 [W.P.(C)No.6839/2023]. 5. The petitioner in these writ petitions has laid a challenge to six separate assessment orders of even date i.e., 28.03.2023 passed under Section 153C read with Section 144 of the Income Tax Act, 1961 [in short, Act ] .....

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..... rain from initiating penalty proceedings, there has been no movement in the matter. 10. Given this position, we are of the view, that the AO had put the petitioner on an extremely tight leash. The AO expected the petitioner to gather information for six AYs within two days, which by any yardstick was not a practical timeframe. 10.1 This is especially so, as the AO, while issuing notice under Section 153C of the Act, had granted 30 days to the petitioner to file the return of income concerning the AYs in issue. 11. Thus, for the foregoing reasons, we are inclined to set aside the impugned assessment orders. 12. It is ordered accordingly. 13. Given this position, the consequent demand notices issued under Section 156 of the Act .....

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