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1 - 3 of 3 (0.19 seconds)Section 148 in The Income Tax Act, 1961 [Entire Act]
Hexaware Technologies Ltd vs Assistant Commissioner Of Income Tax, ... on 29 March, 2022
3. We have also been apprised of the judgments rendered by
different High Courts including the Bombay High Court in
Hexaware Technologies Ltd vs. Assistant Commissioner of
Income Tax [2024 SCC OnLine Bom 1249] and Kairos Properties
Private Limited vs. Assistant Commissioner of Income Tax
[2024:BHC-OS:11962-DB] as well as the Punjab and Haryana High
Court in Jatinder Singh Bhangu vs. Union of India
[2024:PHHC:090942-DB] where cognizance was taken of what has
been described to be an Office Memorandum dated 20 February
2023. From a reading of those judgments it would appear that the
Memorandum has been recognized as instructions issued by the
Central Board of Direct Taxes ["CBDT"]. However, a closer
examination of those communications would reveal that they were
merely instructions provided to learned counsels appearing in certain
legal cases and in that sense may not be liable to be construed as a
principled view expressed by the CBDT in accordance with Section
119 of the Income Tax Act ["Act"]. This since, they were at best
privileged communications between the respondents in those matters
and their counsel.
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