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2024 (11) TMI 1322

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..... Mr.S.Anandh, learned counsel for the petitioner would submit that initially, a show cause notice was issued to the petitioner under Section 148 (b) dated 30.03.2023, on the ground of escaped assessment based on two informations and subsequently, another show cause notice in respect of the same issue, that the petitioner filed replies to the show cause notices on 07.04.2024 and 11.04.2023 pursuant to which, an order was passed under Section 148 A(d) dated 13.04.2024 and a notice under Section 148 dated 13.04.2023 was issued. 2.1 The learned counsel assailed the impugned order/notices by contending that the respondent issued two show cause notices under Section 148 A (b) dated 30.03.2023 and 31.03.2023, first show cause notice was based on .....

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..... t the 4. I have given due considerations to the submissions made on either side and perused the materials available on record. 5. The petitioner is an assessee on the files of the respondent under the provisions of the Income Tax Act, 1961. For the AY 2019-20, the petitioner was issued with a first show cause notice under Section 148 A (b) of the Income Tax Act, 1961 dated 30.03.2023, on the ground of escaped assessment based on two informations :- i) As per TDS statement - salary excluding HRA/PF amount received from WIPRO Ltd was to the tune of Rs. 31,48,489/-. ii) Interest income of Rs. 8641 received from Vijaya Bank 5.2 Subsequently, the petitioner was issued with second show cause notice under Section 148 A (b) of the Act dated .....

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..... o show cause notices and notice under Section 148 was issued, which, according to the petitioner, suffers from violation of provisions contemplated under Section 148 A (b) and also violation of principles of natural justice, since the respondent was completely silent about the information available with them with regard to the search conducted with the Political Party, in relation to the donation receipt issued by the petitioner for a sum of Rs. 1,74,900/- to political party, therefore, the impugned order/notice both dated 13.04.2023 are liable to be set aside. However, this Court is not inclined to accept the contention of the petitioner for the reason that, the petitioner submitted replies to show cause notices, annexing certain documents .....

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