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Vodafone Idea Ltd vs Centralised Processing Centre Income ... on 1 August, 2022

19. Viewed from the perspective as explained above despite persuasive submissions of the learned Standing Counsel, I do not find any reason to take a different view from that adopted by a learned Single Judge of this Court in Allianz Cornhill Information Services Private Limited, Rep. by its Chief Financial Officer v. Union of India rep. by Secretary, Ministry of Finance (Department of Revenue) and Others [2023 SCC OnLine Ker 11076] and Division Bench of the 2025:KER:42465 W.P.(C).Nos.9520 & 9521 of 2014 35 Bombay High Court in Vodafone Idea Limited v. Central Processing Centre and Others [2023 SCC OnLine Bom 2464]. Assessing Officer is bound to adhere to the time limit stipulated in S.144 C (13 ) of the Income Tax Act and assessment order issued in breach of it shall be invalid.
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