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2020 Supreme(Mad) 1411

T.S.SIVAGNANAM, V.BHAVANI SUBBAROYAN
Seshasayee Paper & Boards Ltd. , Rep. by its Deputy Managing Director & Secretary, V. Pichai – Appellant
Versus
Union of India, Rep. by the Commissioner of Income Tax (Central II), Chennai – Respondent


Advocates Appeared:
For the Appellant :A.L. Somayaji, SC, G. Baskar, M.P. Senthilkumar, Advocates.
For the Respondents: A.P. Srinivas, SSC assisted by A.N.R. Jayaprathap, JSC.

JUDGMENT :

T.S. Sivagnanam, J.

(Prayer: APPEALS under Clause 15 of the Letters Patent against the common order dated 25.1.2019 made in W.P.Nos.12604, 33239 and 12603 of 2002.)

1. These appeals are directed against the common order dated 25.1.2019 made in W.P.Nos.12603, 12604 and 33239 of 2002 filed by the appellant.

2. All the three writ petitions were filed by the appellant challenging the notice issued by the second respondent herein under Section 148 of the Income Tax Act, 1961 (for brevity, the Act).

3. The facts, which are essential for the disposal of these appeals, are as hereunder:

    The appellant (hereinafter referred to as the assessee) is a public limited company, which had questioned the proceedings issued by the second respondent – Assessing Officer. The assessment years, which are subject matter of consideration, are 1995-96, 1996-97 and 1997-98. Since the facts are identical for all the three assessment years, it would suffice to refer to the facts relating to the assessment year 1995-96.

4. The assessee filed the return of income for the assessment year 1995-96, in whic

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