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TMI Blog2022 (5) TMI 840X X X X Extracts X X X X X X X X Extracts X X X X ..... efore the authorities concerned to the impugned notices. - W.P.No.12189 of 2022 And W.M.P.Nos.11639, 11646 and 11648 of 2022 - - - Dated:- 6-5-2022 - Honourable Mrs. Justice S.Ananthi For the Petitioner : Ms.Narmadha Sampath For the Respondents : Ms.Hema Murali Krishnan ORDER By consent of both parties, this Writ Petition is taken up for final disposal at the admission stage itself. 2. The case of the petitioner in brief: The petitioner company was incorporated under the Companies Act, 1956 and it is running the business of software development and software services for several years and have executed several projects for Governmental and private agencies successfully. The petitioner's company is also enga ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 0721879(1) dated 14.03.2022 under Section 148A(b) of the Income Tax Act, 1961, has been issued with the prior approval of Principal Commissioner of Income Tax to show cause as to why a Notice under Section 148 of Income Tax Act, should not be issued on the basis of information available as per the notice suggesting that income chargeable to tax has escaped assessment and required the petitioner herein to show cause by 21.03.2022. The petitioner has filed their reply on 14.03.2022 and 18.03.2022 to the aforesaid notice dated 14.03.2022, stating that the companies have been merged and the petitioner has already included the income of Rs.4,74,04,205/- which belongs to GI Hospitalities Pvt. Ltd in the books of GI Retail Pvt. Ltd while filing th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er Section 148 of Income Tax Act. 5. According to the petitioner, M/s. GI Hospitalities Private Limited has been merged with the petitioner company viz., M/s. GI Retail Pvt. Ltd., as per the order of this Court dated 07.11.2016. But, notices were sent under Section 148 of Income Tax Act, by the Income Tax Officer for the year 2018-2019. In the reply vide letters dated 18.03.2022 and 30.03.2022, the petitioner company itself admitted that they have received an income of Rs.4,74,04,205/- which has been accounted in the Books of Account of GI Retail Pvt. Ltd., and the same was reflected in the 26AS of PAN No.AADCG9089R of GI Hospitalities Private Limited. Therefore, it is the contention of the respondent department that even after the merge ..... X X X X Extracts X X X X X X X X Extracts X X X X
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