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2021 Supreme(Mad) 881

S.M.SUBRAMANIAM
Madras Race Club, Rep. , by its Additional Secretary, S. Aruna – Appellant
Versus
Deputy Commissioner of Income-tax, Company Circle IV(1), Nungambakkam – Respondent


Advocates:
Advocate Appeared:
For the Petitioner:G. Baskar, Advocate.
For the Respondent: Hema Muralikrishnan, Senior Standing Counsel.

JUDGMENT :

(Prayer: Petitions filed under Article 226 of the Constitution of India praying for issuance of Writ of Certiorari to call for the records in PAN: AAACM7640R dated 11.01.2013 and 24.10.2014 relating to Assessment Year 2007-08 on the file of the respondent and quash the same.)

W.P.No.3005 of 2013 is preferred challenging the proceedings dated 11.01.2013 issued by the Deputy Commissioner of Income Tax, Company Circle IV(1), Chennai regarding proposal to complete the assessment and calling for objections on initiation of proceedings under Section 147 of the Income Tax Act, 1961 (hereinafter referred to as “the IT Act”). Notice under Section 148 of the IT Act was issued on 20.04.2011. On receipt of the notice under Section 148 of the IT Act, issued for reopening of the assessment for the assessment year 2007-08, the petitioner sent reply to the notice requesting for the reasons for reopening. When the writ petition was taken up for hearing on 06.02.2013, it was admitted and an order of interim stay of all further proceedings was granted by this Court.

2. The learned counsel appearing on behalf of the petitioner made a submission that the petitioner-Club is incorporated in terms

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