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2015 (9) TMI 664

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..... year 2006-07 and ₹ 2,06,00,000 for the assessment year 2007-08. Petitioner did not make the payments immediately thereafter but did so only after coercive steps were taken by attaching the Bank accounts and property of the petitioner, whence ₹ 35 lakhs was paid on 8.5.2014 and the balance of ₹ 75,21,573/- on 20.1.2015 for the assessment year 2006-07, while for the assessment year 2007-08 ₹ 15 lakhs was paid on 11.9.2014 and ₹ 1,11,75,366/- on 20.1.2015. Despite the laxity on the part of the Department in the matter of recovery of the taxes by reason of which petitioner was in possession of the amounts due and payable as tax for almost ten years from the assessment year 2006-07, yet again speaks volumes of the c .....

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..... sment year 2006-2007 and ₹ 1,56,00,000/- for the assessment year 2007- 2008 inter alia stating that the assessee had not commenced trading business, but purchased immovable properties during the assessment year 2006-07, however did not disclose the source of consideration for purchase of the immovable properties. The return for the year 2006-2007 was accepted under Section 143(3) of the 'Act', while the return for the assessment year 2007-2008 income when assessed at ₹ 2,06,00,000/- on 30.12.2010 made a demand for ₹ 1,26,75,366/-. The Prl. Commissioner for Income Tax issued notice dated 20.04.2015 demanding ₹ 63,79,085/- as interest levied under Section 220(2) of the Act for the assessment year 2007-2008. .....

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..... kept in mind, petitioner, a partnership firm, did not submit its returns for the year 2006-07 and 2007-08 within the time stipulated but did so only after the machinery provided under the Income Tax Act was put into force i.e. a search conducted and notice issued, pursuant to which returns were filed on 20.9.2010. The conduct of the petitioner speaks volumes of its commitment to rule of law. The fact that returns submitted when accepted, petitioner was required to pay tax of ₹ 74,74,229/- for the assessment year 2006-07 and ₹ 2,06,00,000 for the assessment year 2007-08. Petitioner did not make the payments immediately thereafter but did so only after coercive steps were taken by attaching the Bank accounts and property of the p .....

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