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TMI Blog2023 (7) TMI 1485X X X X Extracts X X X X X X X X Extracts X X X X ..... a difference between non-consideration at all and improper consideration of a response. It is not a case where objection of the petitioner has not been considered at all though AO has come to a different conclusion. Ground of challenge of the aforesaid impugned order as appears from the argument and submission of petitioner that it revolves around the merit of the impugned order which is based on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ill be at liberty to take all the points raised in this writ petition in course of the proceedings subsequent to the order u/s 148A(d). Ground of the petitioner challenging the notice under Section 148 that after the order u/s 148A(d) which was issued by the jurisdictional assessing officer in case the same should be issued faceless - This is a hyper-technical ground since mode and manner of servi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2019-20 on the ground that petitioner's objection/response to the notice under Section 148A(b) of the Act was not properly considered. There is a difference between non-consideration at all and improper consideration of a response. It is not a case where objection of the petitioner has not been considered at all though assessing officer has come to a different conclusion. Further, ground of chall ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der Section 147 of the Act will have to follow all the procedures like a regular assessment proceeding by issuing notice under Section 142(1), 143(2) of the Act and service of draft assessment order to the petitioner. In view of the discussion made above, I am not inclined to interfere with the aforesaid impugned order under Section 148A(d) of the Act. Petitioner will be at liberty to take all th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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