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2023 (6) TMI 1410

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..... D THAT:- The order to be passed shall be a reasoned order dealing with every objection of petitioner and before passing any such order, a personal hearing shall be granted to petitioner, notice whereof shall be communicated atleast 5 working days in advance. If JAO is going to rely on any judgment, a list thereof shall be provided to petitioner along with the notice for personal hearing so that pe .....

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..... ugned order dated 22/02/2022 was passed and (b) there has been non-application of mind while passing the order dated 22/02/2022. Mr. Gandhi of course also adds that the application for sanction and the approval under Section 151 of the Act has been made available despite called for only in the affidavit-in-reply. 3. The fact that no personal hearing was given is not disputed. 4. On the ground of .....

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..... be presumed to include the amount of gross receipts of the assessee." This finding is incorrect inasmuch as the reasons recorded itself indicate that cash deposit in the account is only Rs. 3,94,600/- and non-cash is Rs. 81,99,997/-. Mr. Gandhi further submitted that in paragraphs 5 and 6 of the impugned order also there are incorrect findings. These allegations which are made in ground (J) to the .....

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..... ch Mr. Gandhi undertakes will be filed within 2 weeks from today. 8. The order to be passed shall be a reasoned order dealing with every objection of petitioner and before passing any such order, a personal hearing shall be granted to petitioner, notice whereof shall be communicated atleast 5 working days in advance. 9. If JAO is going to rely on any judgment, a list thereof shall be provided to .....

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