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2023 (11) TMI 40

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..... re has been a breach of principles of natural justice inasmuch as the respondents/revenue have moved away from what was proposed in the two emails - HELD THAT:- The infraction of principles of natural justice is also sought to be buttressed by emphasising the point that although the petitioner was given twenty-one (21) days to respond to the first of the above-captioned emails concerning adjustmen .....

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..... sel with Mr Shivendra Singh, Mr Puneet Singhal and Ms Mahima Garg, Advocates. RAJIV SHAKDHER, J. (ORAL): CM APPL. 50190/2023 1. Allowed, subject to just exceptions. W.P.(C) 12722/2023 2. Issue notice. 2.1 Mr Gaurav Gupta, learned senior standing counsel, accepts notice on behalf of the respondent/revenue. 3. Given the directions that we propose to pass, Mr Gupta .....

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..... on 245 of the Act by Respondent No. 2 adjusting the refund due to Petitioner for assessment year 2022-23 against the (erroneous) disputed outstanding tax demand(s) for other assessments years, more particularly against demand for assessment year 2017-18 to the extent of Rs. 30,85,39,301; and c. directing the Respondents to expeditiously grant the refund due to the Petitioner for assessment ye .....

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..... etitioner s case that there has been a breach of principles of natural justice inasmuch as the respondents/revenue have moved away from what was proposed in the two emails referred to hereinabove. 7.1 The infraction of principles of natural justice is also sought to be buttressed by emphasising the point that although the petitioner was given twenty-one (21) days to respond to the first of the .....

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