9911796707
TMI Blog2023 (7) TMI 751X X X X Extracts X X X X X X X X Extracts X X X X ..... s been no movement in the matter. Given this position, we are of the view that the 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. We are inclined to set aside the impugned assessment orders. Decided in favour of assessee. - W.P.(C) 6756/2023 & CM Nos.26417-18/2023,W.P.(C) 6782/2023 & CM Nos.26495-96/2023, W.P.(C) 6829/2023 & CM Nos.26751-52/2023,W.P.(C) 6831/2023 & CM Nos.26758-59/2023, W.P.(C) 6833/2023 & CM Nos.26763-64/2023, W.P.(C) 6836/2023 & CM Nos.26770-71/2023 - - - Dated:- 19-5-2023 - HON'BLE MR. JUSTICE RAJIV SHAKDHER AND HON'BLE MR. JUSTICE GIRISH KATHPALIA Present : ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itions concern Assessment Year (AY) 2014-15 [W.P.(C)No.6756/2023], AY 2019-20 [W.P.(C)No.6782/2023], AY 2017-18 [W.P.(C)No.6829/2023], AY 2018-19 [W.P.(C)No.6831/2023], AY 2015-16 [W.P.(C)No.6833/2023] and AY 2016-17 [W.P.(C)No.6836/2023]. 5. The petitioner in these writ petitions has laid a challenge to six (6) 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 ]. 5.1. Besides this, challenge is also laid to the notices of demand dated 28.03.2023 issued under Section 156 of the Act and notices dated 20.03.2023 issued under Section 142(1) of the Act, in each of the writ petitions. 6. The short ground on which the petitioner seeks to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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. 11.1. 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. 12. To enable the petitioner to file the return of income, clearly, it would have to gather documents and thereafter comply with the directions issued by the AO. 13. Thus, for the foregoing reasons, we are inclined to set aside the impugned assessment orders. It is ordered accordingly. 14. Given this position, the consequential demand notices issued under Sec ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
