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2025 Supreme(Online)(Mad) 72631

IN THE HIGH COURT OF JUDICATURE AT MADRAS
C. Saravanan, J
Sadhana Prakash – Appellant
Versus
The Assistant Commissioner of Income Tax Central Circle 3(1), Chennai – 600 034 – Respondent


Advocates:
For the Appellants/Petitioners: Mr.Varun Ranganathan (in both Wps), Mr.K.Ravi
For the Respondents: Mr.A.P.Srinivasan, Mr.A.N.R.Jayaprathap

Table of Content
1. challenge to the jurisdiction of notices under section 148 of the income tax act. (Para 2 , 3)
2. details regarding the nature of the assessment and the petitioners' connections. (Para 4 , 5)
3. natural justice and the rights to cross-examine witnesses. (Para 10 , 17)
4. clarifications on the operation of sections 147, 148, and 153a of the income tax act. (Para 19 , 20 , 22 , 23)
5. final ruling and dismissal of the petitions. (Para 30)

COMMON ORDER

In these two writ petitions, the petitioners had challenged the respective impugned notices issued under Section 148 of the Income Tax Act, 1961 for the assessment year 2017-18 both dated 30.03.2021 and the assessment orders passed under Section 147 of the Income Tax Act against both the petitioners.

2.The petitioners, who are daughter-in-law and mother-in-law, are before this Court. The respective impugned orders were proceeded by respondents under Section 148 of the Income Tax Act, pursuant to which, the respective petitioners filed their return of income. The petitions were furnished with the reasons for issuance of notices under of the Income Tax Act, 1961 vide notice under 143(2) dated 31.11.2021.

3.The reasons for r

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