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2024 (7) TMI 510

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..... ers have not filed objections before the Dispute Resolution Panal (DRP) as is contemplated u/s 144C(2) HELD THAT:- The respective petitioners appear to have entertained a view that the objections with the respondent were sufficient for the purpose of Section 144C(2) of the Income Tax Act, 1961, though the petitioners ought to have filed their objections not only with the respondent but also with the Dispute Resolution Panel. The objections of the petitioners, which has been considered by the respondents, were an incomplete representation by the objections of the petitioners as it ought to have been filed before the Dispute Resolution Panel. Under these circumstances, we inclined to dispose of these writ petitions by quashing the impugned or .....

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..... mployee in UAE and that the amounts are not liable to be taxed and that the petitioner had replied to the draft assessment order on 30.04.2024. 3. The case of the petitioner in W.P.(MD) No.13938 of 2024 is also same that the fixed deposit was reinvested after they have matured with the interest accrued thereon and that the respective petitioners had filed an objection with the respondents. 4. It is submitted that the respondents on the other hand have rejected the objections filed by the respective petitioners dated 30.04.2024 and 11.04.2024 on the ground that the petitioners have not filed objections before the Dispute Resolution Panal (DRP) as is contemplated under Section 144C(2) of the Income Tax Act, 1961. 5. The learned Senior Counsel .....

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..... rders do not call for any interference. 10. I have considered the arguments advanced by the learned Senior Counsel for the petitioners and the learned Senior Standing Counsel for the respondents. 11. The respective petitioners appear to have entertained a view that the objections with the respondent were sufficient for the purpose of Section 144C(2) of the Income Tax Act, 1961, though the petitioners ought to have filed their objections not only with the respondent but also with the Dispute Resolution Panel. The objections of the petitioners, which has been considered by the respondents, were an incomplete representation by the objections of the petitioners as it ought to have been filed before the Dispute Resolution Panel. 12. Under these .....

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