9911796707
TMI Blog2022 (6) TMI 1121X X X X Extracts X X X X X X X X Extracts X X X X ..... ition is impugning notice dated 29/3/2019 issued under Section 148 of the Income Tax Act, 1961 (the said Act) for Assessment Year 2012-2013 and ad-interim stay was granted by order dated 28/11/2013 and that has been in force till date. 2. Without going into the details Section 151 of the said Act provides that no notice shall be issued under Section 148 of the said Act by the Assessing Officer af ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reasons, mechanically. Reason for us to make this observation is that reason recorded by the Assessing Officer contain contradictions, which if the Commissioner had bothered to read would have come to his notice and he could have taken appropriate remedial measures. 3. Mr. Suresh Kumar states that contradictions/errors in the reasons are typographical errors. We do not agree with the same, it ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... de and only requirement to initiate proceeding under Section 147 of the said Act is reason to believe which has been recorded above." 4. Moreover petitioner is a company in the business of carrying on business of jewellery and bullion trade whereas in the reasons it is alleged that petition has failed to disclose truly and fully all material facts relevant to "salary" of which income chargeable t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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