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2024 Supreme(Jhk) 59

RONGON MUKHOPADHYAY, DEEPAK ROSHAN
Pasari Casting and Rolling Mills Private Ltd. – Appellant
Versus
Income-tax Department through its National Faceless Assessment Centre – Respondent


Advocates Appeared:
For the Petitioner: M/s. Kartik Kurmi, N.K. Pasari & Sidhi Jalan.
For the Respondents: Mr. R.N. Sahay, Sr. S.C., Mr. Anurag Vijay, Jr. S.C.

JUDGMENT :

Deepak Roshan, J.

Heard learned counsel for the parties.

2. The instant application has been preferred by the petitioner for the following reliefs: -

    (a) For quashing the Assessment Order dated 31.03.2022 bearing no. ITBA/AST/S/147/2021-22/1042312253(1) whereby an addition of Rs.15,54,42,417/- has been made to the income of the Petitioner in the reassessment proceedings for the Assessment Year 2015-2016 under Section 147 read with Section 144 read with Section 144B of the Income-tax Act, 1961;

(b) For quashing the Notice of Demand under Section 156 of the Income-Tax Act, 1961, dated 31.03.2022 bearing no. ITBA/AST/S/156/2021-22/1042313074(1) pertaining to Assessment Year 2015-2016;

(c) For quashing the Notice for Penalty under Section 274 read with Section 271(1)(c) of the Income-Tax Act, 1961, dated 31.03.2022 bearing ITBA/PNL/S/271(1)(c)/2021-22/1042312815(1) pertaining to Assessment Year 2015-2016;

(d) For a direction upon the Respondents to produce entire records pertaining to the reassessment proceedings of the Petitioner for the Assessment Year 2015-2016;

(e) For a declaration that the entire reassessment proceedings have been conducted in gross violation of Princip

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