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2021 Supreme(Mad) 2744

M.SUNDAR
Jothi Malleables P Ltd. , (Rep by its Managing Director), Tiruchirapalli – Appellant
Versus
Assistant Commissioner of Income Tax, Central Circle – 1, Income Tax Department, Williams Road, Cantonment Trichy – Respondent


Advocates Appeared:
For the Petitioner:A.S. Sriraman, Advocate.
For the Respondents:N. Dilip Kumar, Senior Standing Counsel Assisted by P. Ajitha, Advocate.

JUDGMENT :

(Prayer: Writ Petition filed under Article 226 of the Constitution of India for issuance of Writ of Certiorari, to call for the records of the Writ Petitioner / Assessee on the file of the First Respondent to quash the impugned notice u/s 148 of the Act dated 19.01.2021 in DIN and Notice No.ITBA/AST/S/148/2020-21/1029885993(1) for the assessment year 2018-19 for want of jurisdiction.)

1. In the captioned main writ petition a notice dated 19.01.2021 bearing Reference No.ITBA/AST/S/148/2020-21/1029885993(1) qua assessment year 2018-19 regarding the writ petitioner [hereinafter 'impugned notice' for the sake of convenience and clarity] has been called in question. To be noted assessment year 2018-19 shall hereinafter be referred to as 'said AY' for the sake of convenience and clarity.

2. Owing to the narrow compass on which the captioned main writ petition turns, with the consent of Mr.A.S.Sriraman, learned Counsel on record on behalf of writ petitioner and Mr.N.Dilip Kumar, learned Senior Standing Counsel assisted by Ms.P.Ajitha, who accepted notice on behalf of both the respondents, captioned main writ petition was taken up and heard out.

3. Notwithstanding several grounds th

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