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TMI Blog2022 (10) TMI 548X X X X Extracts X X X X X X X X Extracts X X X X ..... missions advanced by the petitioner in its replies dated 9th June, 2022 and 28th June, 2022. Since the impugned order and the notice issued u/s 148 are non-reasoned, the same are set aside and the matter is remanded back to the AO for a fresh consideration u/s 148A(d) - AO shall pass a fresh reasoned order in accordance with law within eight weeks. This Court clarifies that the AO shall be at l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Act ] as well as the order passed under Section 148A(d) of the Act and the notice issued under Section 148 of the Act both dated 30th May, 2022 for the Assessment Year 2013-14. 2. Learned counsel for the petitioner submits that the impugned order and notice are void ab initio as they have been issued in the name of Scilla Town Planners Pvt. Ltd. [ STPPL ], a non-existent entity as it had mer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that STTPL, petitioner as well as M/s Wave One Pvt. Ltd. belong to one common group. He emphasises that scrutiny assessments had taken place in the case of M/s Wave One Pvt. Ltd. as well as M/s Uppal Chadha Hi-Tech Developers Pvt. Ltd. in the assessment year 2013-14 itself and the said loan transaction had been examined. 6. Issue notice. Mr.Puneet Rai, Senior Standing Counsel for the responden ..... X X X X Extracts X X X X X X X X Extracts X X X X
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