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Petitioner is that the fact that this O-3 notice is backdated is evident from the notice which is titled as "Form ... notices in a backdated manner. The same being backdated is, prima facie, evident from the use of the title "Form

other hand, the Assessing Officer held that the assessee had backdated the transaction of transfer of shares as the market price of NIIT shares

Petitioner is that the fact that this O-3 notice is backdated is evident from the notice which is titled as "Form