CHANDRASHEKHAR Vs. ASSESSING OFFICER, JCIT (OSD)

JUDGEMENT

(1.) In this petition the petitioner seeks the impugned notices at Annexures-A to A5 all dated 03.09.2021, impugned notices at Annexures-B to B15 all dated 22.09.2021, impugned order at Annexures-C to C8 all dated 20.09.2021 and for other reliefs.

(2.) Heard learned counsel for the petitioner, learned counsel for the respondents and perused the material on record.

(3.) In addition to reiterating the various contentions urged in the Memorandum of Petition and referring to the documents produced by the petitioner, learned counsel for the petitioner submits that the impugned notices and the impugned order are without jurisdiction or authority of law and the same are illegal and arbitrary in view of the circulars dated 02.02.1993, 06.03.1989 and 16.01.1991 passed by the Central Board of Direct Taxes, which have been referred to and affirmed by this Court as well as the Hon'ble High Courts of Bombay and Madras. In this context, it is submitted that prior to the issuance of the impugned notices, the petitioner submitted stay applications on 31.08.2021 vide Annexures-F to F6 and consequently, the subsequent impugned notices and impugned orders are illegal and arbitrary and the same deserve to be quashed.