SHRI. SUNIL VISHNU NAIK vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

WP/104929/2022HC KarnatakaKAHC02018242202121 June 2023Bench: S.VISHWAJITH SHETTY21 pages

AI SummaryPartly Allowed

What did the High Court hold?

The High Court of Karnataka, Dharwad Bench, disposed of the writ petitions with a specific direction. The Court acknowledged that the First Appellate Authority had already disposed of the appeals on 10.12.2021, and the petitioners had subsequently filed second appeals before the Income Tax Appellate Tribunal. The Court directed the Income Tax Appellate Tribunal to dispose of these second appeals, which challenged both the original assessment order dated 31.01.2014 and the order of the First Appellate Authority dated 10.12.2021, as expeditiously as possible. The disposal was mandated to be completed not later than a period of four months from the date of receipt of a certified copy of the High Court's order. No specific findings were made on the merits of the assessment orders themselves, as the petitions were disposed of based on the parties' submissions regarding the expeditious disposal of pending appeals.

What were the facts?

The petitioners, including Shri. Sunil Vishnu Naik and Shri. Raju S/o Bhalchandra Honule, filed multiple writ petitions challenging assessment orders passed by the Assistant Commissioner of Income Tax, Central Circle-I, Belagavi, for various Assessment Years (AYs) including 2006-07, 2009-10, 2011-12, 2007-08, 2008-09, 2010-11, 2012-13. The initial assessment orders were dated 31.01.2014. The petitioners also sought directions for the Commissioner of Income Tax (Appeals) to dispose of their appeals against these assessment orders. During the pendency of the writ petitions, the First Appellate Authority disposed of the appeals on 10.12.2021. Subsequently, the petitioners filed second appeals before the Income Tax Appellate Tribunal (ITAT).

What were the issues?

1. Whether the High Court should issue a writ of certiorari to quash the assessment orders dated 31.01.2014 passed by the Assistant Commissioner of Income Tax for various Assessment Years. 2. Whether the High Court should direct the Commissioner of Income Tax (Appeals) to dispose of the appeals filed by the petitioners against the assessment orders. Assessee's Contentions: The petitioners contended that the writ petitions could be disposed of with a direction to the Income Tax Appellate Tribunal to dispose of the second appeals filed by them, challenging the original assessment orders and the orders of the First Appellate Authority, within a specified timeframe. Revenue's Contentions: The learned counsel for the respondents (Revenue) submitted that they had no objection to issuing such a direction.

AI-generated summary — verify with the full judgment below

Heard together (16 matters)

WP No. 104929 of 2022

WP No. 103482 of 2022

WP No. 103485 of 2022

WP No. 103493 of 2022

WP No. 105014 of 2022

WP No. 105016 of 2022

WP No. 105018 of 2022

WP No. 102874 of 2023

WP No. 102875 of 2023

WP No. 102876 of 2023

WP No. 102877 of 2023

WP No. 102878 of 2023

WP No. 102879 of 2023

WP No. 102880 of 2023

WP No. 102881 of 2023

WP No. 103353 of 2023

Read from the judgment's own cause title. This page is filed under one of them.

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WP No. 104929 of 2022 C/W WP No. 103482 of 2022, WP No. 103485 of 2022, WP No. 103493 of 2022, WP No. 105014 of 2022, WP No. 105016 of 2022, WP No. 105018 of 2022, WP No. 102874 of 2023, WP No. 102875 of 2023, WP No. 102876 of 2023, WP No. 102877 of 2023, WP No. 102878 of 2023, WP No. 102879 of 2023, WP No. 102880 of 2023, WP No. 102881 of 2023, WP No. 103353 of 2023 IN THE HIGH COURT OF KARNATAKA, DHARWAD BENCH DATED THIS THE 21ST DAY OF JUNE, 2023 BEFORE THE HON'BLE MR JUSTICE S.VISHWAJITH SHETTY WRIT PETITION NO. 104929 OF 2022 (T-IT) C/W WRIT PETITION NO. 103482 OF 2022 WRIT PETITION NO. 103485 OF 2022 WRIT PETITION NO. 103493 OF 2022 WRIT PETITION NO. 105014 OF 2022 WRIT PETITION NO. 105016 OF 2022 WRIT PETITION NO. 105018 OF 2022 WRIT PETITION NO. 102874 OF 2023 WRIT PETITION NO. 102875 OF 2023 WRIT PETITION NO. 102876 OF 2023 WRIT PETITION NO. 102877 OF 2023 WRIT PETITION NO. 102878 OF 2023 WRIT PETITION NO. 102879 OF 2023 WRIT PETITION NO. 102880 OF 2023 WRIT PETITION NO. 102881 OF 2023 WRIT PETITION NO. 103353 OF 2023 IN W.P. NO. 104929 OF 2022: BETWEEN:

SHRI. SUNIL VISHNU NAIK, AGE. 55 YEARS, OCC. BUSINESS, R/O. #1, KALYAN NAGAR, VADAGAON, BELAGAVI. … PETITIONER RAKESH S HARIHAR Digitally signed by RAKESH S HARIHAR Location: Dharwad Date: 2023.06.24 10:42:17 +0530

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2006- 07 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 103482 OF 2022 : BETWEEN:

SHRI. RAJU S/O BHALCHANDRA HONULE, AGE. 51 YEARS, OCC. BUSINESS, R/O. HOUSE NO. 34, DHARMAVEER SAMBHAJI NAGAR, VADGAON, BELAGAVI.

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WP No. 104929 of 2022 C/W WP No. 103482 of 2022, WP No. 103485 of 2022, WP No. 103493 of 2022, WP No. 105014 of 2022, WP No. 105016 of 2022, WP No. 105018 of 2022, WP No. 102874 of 2023, WP No. 102875 of 2023, WP No. 102876 of 2023, WP No. 102877 of 2023, WP No. 102878 of 2023, WP No. 102879 of 2023, WP No. 102880 of 2023, WP No. 102881 of 2023, WP No. 103353 of 2023 … PETITIONER (BY SRI. SANGRAM S KULKARNI, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I, BELAGAVI, FEROJ KHIMJIBHAI COMPLEX, OPPOSITE CIVIL HOSPITAL, DR. B. R. AMBEDKAR ROAD, BELAGAVI-590001. 2. THE COMMISSIONER OF INCOME TAX (APPEALS), BELAGAVI, FEROJ KHIMJIBHAI COMPLEX, OPPOSITE CIVIL HOSPITAL, DR. B. R. AMBEDKAR ROAD, BELAGAVI-590001. 3. THE COMMISSIONER OF INCOME TAX (APPEALS), PANAJI, HAVING OFFICE AT PANAJI 3RD FLOOR, PUNDALIK NIWAS, RUA DE QUREM, PANAJI, GOA-403001. … RESPONDENTS (BY SRI. Y V RAVIRAJ, ADVOCATE)

THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2006- 07 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 103485 OF 2022 : BETWEEN:

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SHRI. RAJU S/O. BHALCHANDRA HONULE, AGE. 51 YEARS, OCC. BUSINESS, R/O. HOUSE NO.34, DHARMAVEER SAMBHAJI NAGAR, VADGAON, BELAGAVI. … PETITIONER (BY SRI. SANGRAM S KULKARNI, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I, BELAGAVI, FEROJ KHIMJIBHAI COMPLEX, OPPOSITE CIVIL HOSPITAL, DR. B. R. AMBEDKAR ROAD, BELAGAVI-590001. 2. THE COMMISSIONER OF INCOME TAX (APPEALS), BELAGAVI, FEROJ KHIMJIBHAI COMPLEX, OPPOSITE CIVIL HOSPITAL, DR. B. R. AMBEDKAR ROAD, BELAGAVI-590001. 3. THE COMMISSIONER OF INCOME TAX (APPEALS), PANAJI, HAVING OFFICE AT PANAJI 3RD FLOOR, PUNDALIK NIWAS, RUA DE QUREM, PANAJI, GOA-403001. … RESPONDENTS (BY SRI. Y V RAVIRAJ, ADVOCATE)

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SHRI. RAJU S/O. BHALCHANDRA HONULE AGE. 51 YEARS, OCC. BUSINESS, R/O. HOUSE NO.34, DHARMAVEER SAMBHAJI NAGAR, VADGAON, BELAGAVI. … PETITIONER (BY SRI. SANGRAM S KULKARNI, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I, BELAGAVI, FEROJ KHIMJIBHAI COMPLEX, OPPOSITE CIVIL HOSPITAL, DR. B. R. AMBEDKAR ROAD, BELAGAVI-590001. 2. THE COMMISSIONER OF INCOME TAX (APPEALS), BELAGAVI, FEROJ KHIMJIBHAI COMPLEX, OPPOSITE CIVIL HOSPITAL, DR. B. R. AMBEDKAR ROAD, BELAGAVI-590001. 3. THE COMMISSIONER OF INCOME TAX (APPEALS), PANAJI, HAVING OFFICE AT PANAJI 3RD FLOOR, PUNDALIK NIWAS, RUA DE QUREM, PANAJI, GOA-403001. … RESPONDENTS (BY SRI. Y V RAVIRAJ, ADVOCATE)

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2011- 12 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 105014 OF 2022 : BETWEEN:

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2007- 08 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 105016 OF 2022 : BETWEEN:

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2006- 07 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 105018 OF 2022 : BETWEEN:

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WP No. 104929 of 2022 C/W WP No. 103482 of 2022, WP No. 103485 of 2022, WP No. 103493 of 2022, WP No. 105014 of 2022, WP No. 105016 of 2022, WP No. 105018 of 2022, WP No. 102874 of 2023, WP No. 102875 of 2023, WP No. 102876 of 2023, WP No. 102877 of 2023, WP No. 102878 of 2023, WP No. 102879 of 2023, WP No. 102880 of 2023, WP No. 102881 of 2023, WP No. 103353 of 2023 CENTRAL CIRCLE-I, BELAGAVI, FEROJ KHIMJIBHAI COMPLEX, OPPOSITE CIVIL HOSPITAL, DR. B. R. AMBEDKAR ROAD, BELAGAVI-590001. 2. THE COMMISSIONER OF INCOME TAX (APPEALS), BELAGAVI, FEROJ KHIMJIBHAI COMPLEX, OPPOSITE CIVIL HOSPITAL, DR. B. R. AMBEDKAR ROAD, BELAGAVI-590001. 3. THE COMMISSIONER OF INCOME TAX (APPEALS), PANAJI, HAVING OFFICE AT PANAJI 3RD FLOOR, PUNDALIK NIWAS, RUA DE QUREM, PANAJI, GOA-403001. … RESPONDENTS (BY SRI. Y V RAVIRAJ, ADVOCATE)

THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2010- 11 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 102874 OF 2023 : BETWEEN:

SHRI. SHAM @ GANGADHAR VAIJNATHRAO MUCHANDI, AGE. 60 YEARS, OCC. BUSINESS, R/O. # 357, ANADWADI, SHAHAPUR, BELAGAVI. … PETITIONER

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2009- 10 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 102875 OF 2023 : BETWEEN:

SHRI. SHAM @ GANGADHAR VAIJNATHRAO MUCHANDI, AGE. 60 YEARS, OCC. BUSINESS, R/O. # 357, ANADWADI, SHAHAPUR, BELAGAVI. … PETITIONER

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2006- 07 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 102876 OF 2023: BETWEEN:

SHRI. SHAM @ GANGADHAR VAIJNATHRAO MUCHANDI, AGE. 60 YEARS, OCC. BUSINESS, R/O. # 357, ANADWADI, SHAHAPUR, BELAGAVI. … PETITIONER

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2007- 08 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 102877 OF 2023 : BETWEEN:

SHRI. SUNIL VISHNU NAIK AGE. 55 YEARS, OCC. BUSINESS, R/O. #1, KALYAN NAGAR, VADAGAON, BELAGAVI. … PETITIONER

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2007- 08 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 102878 OF 2023 : BETWEEN:

SHRI. SUNIL VISHNU NAIK AGE. 55 YEARS, OCC. BUSINESS, R/O. #1, KALYAN NAGAR, VADAGAON, BELAGAVI. … PETITIONER

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2008- 09 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 102879 OF 2023 : BETWEEN:

SHRI. SUNIL VISHNU NAIK AGE. 55 YEARS, OCC. BUSINESS, R/O. #1, KALYAN NAGAR, VADAGAON, BELAGAVI. … PETITIONER

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2009- 10 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 102880 OF 2023 : BETWEEN:

SHRI. SHAM ALIAS GANGADHAR VAIJNATHRAO MUCHANDI, AGE. 60 YEARS, OCC. BUSINESS, R/O. #357, ANANDWADI, SHAHAPUR, BELAGAVI-590003

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2010- 11 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 102881 OF 2023 : BETWEEN:

SHRI. SHAM @ GANGADHAR VAIJNATHRAO MUCHANDI, AGE. 60 YEARS, OCC. BUSINESS, R/O. #357, ANANDWADI,

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WP No. 104929 of 2022 C/W WP No. 103482 of 2022, WP No. 103485 of 2022, WP No. 103493 of 2022, WP No. 105014 of 2022, WP No. 105016 of 2022, WP No. 105018 of 2022, WP No. 102874 of 2023, WP No. 102875 of 2023, WP No. 102876 of 2023, WP No. 102877 of 2023, WP No. 102878 of 2023, WP No. 102879 of 2023, WP No. 102880 of 2023, WP No. 102881 of 2023, WP No. 103353 of 2023 SHAHAPUR, BELAGAVI-590003 … PETITIONER (BY SRI. SANGRAM S KULKARNI, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I, BELAGAVI, FEROJ KHIMJIBHAI COMPLEX, OPPOSITE CIVIL HOSPITAL, DR. B. R. AMBEDKAR ROAD, BELAGAVI-590001. 2. THE COMMISSIONER OF INCOME TAX (APPEALS), BELAGAVI, FEROJ KHIMJIBHAI COMPLEX, OPPOSITE CIVIL HOSPITAL, DR. B. R. AMBEDKAR ROAD, BELAGAVI-590001. … RESPONDENTS (BY SRI. Y V RAVIRAJ, ADVOCATE)

THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2012- 13 VIDE ANNEXURE-'A' & ETC. IN W.P. NO. 103353 OF 2023 : BETWEEN:

SHRI. RAJU S/O BHALCHANDRA HONULE, AGE. 51 YEARS, OCC. BUSINESS, R/O. HOUSE NO. 34,

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WP No. 104929 of 2022 C/W WP No. 103482 of 2022, WP No. 103485 of 2022, WP No. 103493 of 2022, WP No. 105014 of 2022, WP No. 105016 of 2022, WP No. 105018 of 2022, WP No. 102874 of 2023, WP No. 102875 of 2023, WP No. 102876 of 2023, WP No. 102877 of 2023, WP No. 102878 of 2023, WP No. 102879 of 2023, WP No. 102880 of 2023, WP No. 102881 of 2023, WP No. 103353 of 2023 DHARMAVEER SAMBHAJI NAGAR, VADGAON, BELAGAVI. … PETITIONER (BY SRI. SANGRAM S KULKARNI, ADVOCATE) AND: 1. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I, BELAGAVI, FEROJ KHIMJIBHAI COMPLEX, OPPOSITE CIVIL HOSPITAL, DR. B. R. AMBEDKAR ROAD, BELAGAVI-590001. 2. THE COMMISSIONER OF INCOME TAX (APPEALS), BELAGAVI, FEROJ KHIMJIBHAI COMPLEX, OPPOSITE CIVIL HOSPITAL, DR. B. R. AMBEDKAR ROAD, BELAGAVI-590001. … RESPONDENTS (BY SRI. Y V RAVIRAJ, ADVOCATE)

THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA, PRAYING TO ISSUE A WRIT OF CERTIORARI AND QUASH THE IMPUGNED ASSESSMENT ORDERS DATED 31.01.2014 PASSED BY THE RESPONDENT NO.1 THE ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-I, BELAGAVI FOR THE AY 2012- 13 VIDE ANNEXURE-'B' & ETC.

THESE PETITIONS, COMING ON FOR ORDERS, THIS DAY, THE COURT MADE THE FOLLOWING:

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WP No. 104929 of 2022 C/W WP No. 103482 of 2022, WP No. 103485 of 2022, WP No. 103493 of 2022, WP No. 105014 of 2022, WP No. 105016 of 2022, WP No. 105018 of 2022, WP No. 102874 of 2023, WP No. 102875 of 2023, WP No. 102876 of 2023, WP No. 102877 of 2023, WP No. 102878 of 2023, WP No. 102879 of 2023, WP No. 102880 of 2023, WP No. 102881 of 2023, WP No. 103353 of 2023 ORDER 1. Learned counsel Sri.Y.V.Raviraj is directed to take notice for respondents. 2. These writ petitions are filed challenging the impugned assessment order for the Assessment Year 2006-07, which was passed by the 1st respondent on 31.01.2014. The prayer is also made to direct the 2nd respondent appellate authority to dispose of the appeals filed by the petitioner against the Assessment Order at Annexure – A, dated 31.01.2014. 3. During the pendency of these writ petitions, it appears that the First Appellate Authority has already disposed off the appeals on 10.12.2021 and as against the said order, the petitioners have filed the second appeals before the Income Tax Appellate Tribunal.

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WP No. 104929 of 2022 C/W WP No. 103482 of 2022, WP No. 103485 of 2022, WP No. 103493 of 2022, WP No. 105014 of 2022, WP No. 105016 of 2022, WP No. 105018 of 2022, WP No. 102874 of 2023, WP No. 102875 of 2023, WP No. 102876 of 2023, WP No. 102877 of 2023, WP No. 102878 of 2023, WP No. 102879 of 2023, WP No. 102880 of 2023, WP No. 102881 of 2023, WP No. 103353 of 2023 4. Learned counsel appearing for the petitioner submits that the writ petitions could be disposed off with a direction to the Income Tax Appellate Tribunal to dispose off the second appeals filed by the petitioners challenging the order at Annexure - A, dated 31.01.2014, passed by the 1st respondent and the order dated 10.12.2021, passed by the Commissioner of Income Tax (Appeals), Panaji within a time frame. 5. Learned counsel appearing for the respondents submits that he has no objection for issuing such a direction. 6. The submissions made by the learned counsel appearing for the parties are placed on record. 7. Accordingly, these writ petitions are disposed off directing the Income Tax Appellate Tribunal to dispose off the second appeals filed by the petitioner challenging

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