2021 (9) TMI 1527 - HC - Income Tax

Validity of notice issued u/s 153C - writ direction or order to quash and set aside the impugned notices u/s 153C and the order disposing off the objections along with the show Cause Notices issued for A.Y. 2016- 17, A.Y. 2017-18 and A.Y. 2018-19 - HELD THAT - For the reasons to be followed which for the paucity of time, order not being dictated today. The petition is not entertained.

Summary

Issues:
Petition for writ of certiorari and mandamus to quash income tax notices under section 153C and order disposing objections, interim relief, cost of petition, further reliefs.

Analysis:
The petitioner sought various reliefs through the petition, including a writ of certiorari and/or mandamus to quash the impugned notices dated 29/09/2020 under section 153C of the Income Tax Act, 1961, along with the order dated 01/09/2021 disposing off the objections and Show Cause Notices for multiple assessment years. Additionally, interim relief was requested to stay the implementation of the impugned notices and orders until the final outcome of the petition. The petitioner also sought the award of costs and any other reliefs deemed fit by the Hon'ble Court.

The Court, however, decided not to entertain the petition at this stage due to reasons that were not dictated on the same day. The judgment did not delve into the specifics of the reasons for not entertaining the petition, leaving the petitioner without the reliefs sought through the writ petition. The decision to not entertain the petition indicates that the Court did not find merit in the petitioner's claims or that there were procedural or substantive issues that prevented the Court from granting the reliefs requested. As a result, the petition was dismissed without further elaboration on the grounds for such dismissal.

Overall, the judgment reflects the Court's decision to not entertain the petition seeking various reliefs related to income tax notices and objections under the Income Tax Act, 1961. The lack of detailed reasoning provided in the judgment regarding the dismissal of the petition leaves the petitioner with limited insight into the Court's rationale for not granting the reliefs sought. The dismissal of the petition implies that the Court did not find sufficient grounds to proceed with the requested reliefs, leading to the denial of the writ of certiorari, mandamus, interim relief, costs, and any other reliefs sought by the petitioner.