TMI Blog2025 (1) TMI 1414X X X X Extracts X X X X X X X X Extracts X X X X ..... issued an intimation u/s 245 for adjusting the refund against the demand of other years for which Rectification Applications are pending since 2021 - HELD THAT:- Respondents to first adjudicate and pass orders on the Rectification Applications filed for the Assessment Year 2017-2018 to 2020-2021 and thereafter proceed further, if required for adjusting the refund of Assessment Year 2021-2022 agai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ore this Court in the present Petition. X X X X Extracts X X X X X X X X Extracts X X X X ..... refund against the demand of other years for which Rectification Applications are pending since 2021. It is the contention of the Petitioner that if these Rectification Applications are allowed then there would be no demand. 5. In the light of the above facts it is necessary for the Respondents to first adjudicate and pass orders on the Rectification Applications filed for the Assessment Year 201 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... udicate the same on its merits without going into the limitation since the Petitioner was bona fide pursuing the said matter before this Court in the present Petition. 7. In view of the above we propose to pass the following order:- (a) Respondent No. 1 is directed to pass an order deciding the following Rectification Applications filed by the Petitioner and tabulated under for the Assessment Y ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 245 of the IT Act. The Petitioner is directed to file its response within a period of two weeks from the date of the Respondent No. 1 passing the Rectification order for the Assessment Years 2017-2018 to 2020-2021. (c) The Respondents to pass a speaking order on the response filed by the Petitioner pursuant to communication dated 22 January 2025 for Assessment Year 2021-2022 whereby provision of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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