9911796707
TMI Blog2025 (3) TMI 48X X X X Extracts X X X X X X X X Extracts X X X X ..... ,. For the Respondent-Income Tax: Mr Suresh Kumar,. PC:- 1. Heard Mr Pritesh Burad for the Petitioner and Mr Suresh Kumar for the Respondent. 2. The Petitioner challenges the impugned order dated 7 April 2023 made under Section 148A (d) of the Income Tax Act, 1961 (the IT Act) and the consequential impugned notice dated 7 April 2023 made under Section 148 of the IT Act. 3. After hearing th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gations are serious, and it would not be fair to interdict the proceedings at this stage based on the contentions urged. 5. In this case, after the Petitioner received a show-cause notice, he chose not to respond. Mr Pritesh Burad submits that there was no obligation to reply since, according to the petitioner, the notice lacked jurisdiction. Consequently, the petitioner assumed that the impugned ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is stage so as not to prejudice the Petitioner or render it difficult to raise such issues during the assessment proceedings. 7. We only note that, given the facts of the present case and considering the Petitioner's attitude of not responding to the notices, no case is made to exercise our extraordinary jurisdiction and interdict further assessment proceedings. If the Petitioner is confident ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nvestigation into disputed facts would also be necessary. Even the limitation issue, in the peculiar facts of this case, would be a mixed question of law and fact. As noted earlier, this is not a fit case to exercise our discretion and interdict the proceedings. Any such stalling of proceedings will impact the assessments of various assessees covered by the allegations in the communication dated 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
