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TMI Blog2022 (3) TMI 178X X X X Extracts X X X X X X X X Extracts X X X X ..... eld by the petitioner are to be treated as stock-in-trade and not as capital assets and that the petitioner should have computed the income tax liability under the head profits and gains from business or profession and not under the head capital gains - HELD THAT:- As brought to our notice that in response to impugned notice dated 30.03.2021, petitioner has filed its reply on 28.04.2021 inter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... No. 1104 OF 2022 - - - Dated:- 2-3-2022 - HON BLE MR. JUSTICE MOHAMMAD RAFIQ, CHIEF JUSTICE And HON BLE MS. JUSTICE JYOTSNA REWAL DUA FOR THE PETITIONER : MR. AMAR PRATAP SINGH AND MR. ANKIT AWAL, ADVOCATES FOR THE RESPONDENTS : MR. BALRAM SHARMA, ASSISTANT SOLICITOR GENERAL OF INDIA ORDER This petition coming on for admission this day, Hon ble Ms. Justice Jyotsna Rewal Dua ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessing officer has already made an addition of ₹ 40,13,89,726/- to the total income of the petitioner primarily on the ground that the investments held by the petitioner are to be treated as stock-in-trade and not as capital assets and that the petitioner should have computed the income tax liability under the head profits and gains from business or profession and not under the head c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat in response to impugned notice dated 30.03.2021, petitioner has filed its reply on 28.04.2021 inter alia stating therein that the Income Tax Officer/respondent No.2 does not have the jurisdiction to initiate the re-assessment proceedings against the petitioner in light of 3rd proviso to Section 147. This fact has not been denied by learned Senior Counsel for the respondents-department. In ligh ..... X X X X Extracts X X X X X X X X Extracts X X X X
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