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TMI Blog2023 (6) TMI 620X X X X Extracts X X X X X X X X Extracts X X X X ..... the show cause notice - HELD THAT:- Perused the impugned order passed u/s 148A(d) and the reasons clearly no consideration of the replies at Annexures G and J. The impugned order is passed stating that there are no details furnished with regard to source of remittances and purchases. A bare perusal of the table which is a part of the reply at Annexure 'G' would indicate otherwise. Ther ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... espondent No.1 under Section 148 of the Act along with the impugned order dated 31.3.2023 at Annexure-A passed under Section 148A(d) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') and has also challenged the show cause notice at Annexure-C. 2. It is the contention of the petitioner that the order at Annexure-A does not reflect consideration of the replies made by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the assessee while transaction at Sl.No.2 is refund of excess share application money and does not constitute income of the assessee. It is further pointed out that the transaction at Sl.No.6 is only acquisition of arrears which does not constitute income of the assessee. It is pointed that such explanation including other detailed explanation at Annexure-J has not been considered while passing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stating that there are no details furnished with regard to source of remittances and purchases. However, a bare perusal of the table which is a part of the reply at Annexure 'G' would indicate otherwise. There is a case made out for reconsideration of the order under Section 148A(d) of the Act at Annexure-A. Accordingly, the order at Annexure-A is set aside with a direction to the Authorit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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