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In some cases the petitioners have challenged the notice, in some cases the assessment and in other levy of penalty. In all of them the petitioners have challenged the notices or orders passed under Section 148 read with Section 144 of the Income Tax Act, 1961 or the consequent proceedings; those in turn had been passed on a premise that certain amount of money belonged to the petitioners-assessee.

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Section 4, 148 and 144 of the Income-tax Act, 1961—Reassessment — Most appropriate course of action would be that all the impugned orders are quashed and the same be re-decided after considering the objections of the petitioners

Facts: These seven writ petitions involve the same issue. In some cases the petitioners have challenged the notice, in some cases the assessment and in other levy of penalty. In all of them the petitioners have challenged the notices or orders passed under Section 148 read with Section 144 or the consequent proceedings; those in turn had been passed on a premise that certain amount of money belonged to the assessee.

Held, that both the learned counsel have very fairly agreed that most appropriate course of action would be that all the impugned orders are quashed and the same be re-decided (along with those notices which have also been challenged) after considering the objections of the petitioners. - PUNJAB POLICE HOUSING CORPORATION LTD. V/s PR. CHIEF CIT - [2020] 22 ITCD Online 026 (P&H)

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