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TMI Blog2022 (11) TMI 979X X X X Extracts X X X X X X X X Extracts X X X X ..... elieve that income had escaped assessment and whether the Assessing Officer has tangible material before him for the formation of that belief? - HELD THAT:- In view of the settled proposition of law, the submissions of Petitioner that in the reasons to believe it is stated that Odyssey Securities Private Ltd. is a scrip on which Petitioner has done high volume/value transaction, Odyssey Securiti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er is impugning a notice dated 31st March, 2021 issued under Section 148 of the Income Tax Act, 1961 (the said Act) where Respondent No.1 has stated that he has reasons to believe that Petitioner s income chargeable to tax for the assessment year 2015-16 has escaped assessment within the meaning of section 147 of the said Act. At Petitioner s request, the reasons recorded for reopening of assessme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... prove or establish that income has escaped assessment. We find support for this view in Export Credit Guarantee Corporation of India Ltd. vs. Additional Commissioner of Income-Tax and others 2013(30) taxmann.com 211 (Bombay) . In Export Credit Guarantee Corporation of India Ltd. (supra), His Lordship Dr. D.Y. Chandrachud (as he then was), has expressed that a reason to believe at the stage of r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed Company over which SEBI will have no jurisdiction and therefore, reliance of SEBI s order shows non-application of mind and on such reasons when approval has been granted that also indicates non-application of mind by the approving authority etc. will not hold water. We are not willing to accept the submissions of Mr. Jain. We are satisfied, in the facts and circumstances of the case, that ther ..... X X X X Extracts X X X X X X X X Extracts X X X X
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