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TMI Blog2022 (9) TMI 1614X X X X Extracts X X X X X X X X Extracts X X X X ..... t 8(4) and said order is subject matter of appeal before CIT (A) and same is pending - Pending the said civil litigation, respondents cannot take criminal action - HELD THAT:- As the petitioner has filed reply to the said show cause notice and also sought documents on which the respondents intends to rely upon. As respondent nos. 2 and 3 seeks time to make submissions and/or file affidavit upto 17 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Tax Act, 2015. the Learned senior advocate submits that the basis for issuance of show cause notice is the assessment made against the petitioner for the assessment year 2019-2020, by the Deputy Director, Income Tax (Inv) Unit 8(4). The said order is subject matter of appeal before Commissioner of Income Tax (Appeal). The same is pending. In view of that it would be premature at this stage to issu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cannot have retrospective application, is pending for consideration, in various High Courts and in this Court. This Court has admitted Writ Petition bearing Writ Petition No. 1300 of 2018. Similar issue is also for consideration in Writ Petition No. 965 of 2019. Details of the cases pending before this High Court and other High Courts are mentioned in paragraph no. 16 of memo of Writ Petition. 5. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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