2022 (4) TMI 461

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..... nd in the writ petition that Mr. Gaurav Dalmia was a common director in Banyan Real Estate Fund, Mauritius, Landmark Hitech Development Pvt. Ltd. and Landmark Realtech Pvt. Ltd. It is the case of the Revenue that the petitioner s company is owned and controlled by a US Company and consequently the sale of shares by the petitioner to Landmark Realtech Pvt. Ltd. is not entitled to the benefit of .....

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..... tion 148 of the Income Tax Act, 1961 (for short Act ) and order disposing of objections dated 8th December, 2021 for the Assessment Year 2014-15. Learned senior counsel for the petitioner contends that the impugned order is based on palpably false statements viz:- (i) The case of assessee was never selected for scrutiny, therefore the question of change of opinion in case of assessee does .....

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..... it was not disclosed during the original assessment proceeding as well as in the replies to the notice under Section 142(1) and in the writ petition that Mr. Gaurav Dalmia was a common director in Banyan Real Estate Fund, Mauritius, Landmark Hitech Development Pvt. Ltd. and Landmark Realtech Pvt. Ltd. It is the case of the Revenue that the petitioner s company is owned and controlled by a US C .....

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