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TMI Blog2021 (12) TMI 1409X X X X Extracts X X X X X X X X Extracts X X X X ..... S SOPARKAR(6851) ORAL ORDER (PER : HONOURABLE MS. JUSTICE SONIA GOKANI) 1. The petitioner is before this Court under Article 226 of the Constitution of India challenging the notice issued by the respondent under Section 148 of the Income-Tax Act dated 31.03.2021 directing the petitioner to furnish the return of income for the assessment year 2014-15 on the ground that the assumption of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Income-Tax Act determining the income at Rs. 130,80,53,520/-. 2.2. A notice came to be issued on 06.10.2020 where the petitioner was asked to furnish the details such as nature of expanses incurred under Section 35(i)(ii) of the Income-Tax Act, names, PAN and addresses of the parties to whom the payments were made. The petitioner made payment of Rs.65,00,000/- to Shri Arvindo Institute of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion, hearing and final disposal of this petition, to stay implementation and operation of the notice at Annexure A to this petition and stay further proceedings for assessment for A.Y. 2014-15; (d) any other and further relief deemed just and proper be granted in the interest of justice; (e) to provide for the cost of this petition." 3. We have heard learned advocate Mr. B.S.Soparkar appea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e mind of the revenue also, this notice has been issued, and hence, this requires indulgence. 3.1. He has also supported his submissions with follwoing two authorities: - (i) Parashuram Pottery Works Co. Ltd. vs. Income-tax Officer [[1977] 106 ITR 1 (SC)]; (ii) Shree Bansidhar Spg. & Wvg. Mills (P.) Ltd. vs Incometax Officer [[1980] 3 Taxman 576 (Gujarat)]. 4. At this stage, learned advoca ..... X X X X Extracts X X X X X X X X Extracts X X X X
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