TMI Blog2023 (7) TMI 1415X X X X Extracts X X X X X X X X Extracts X X X X ..... reference of some transaction relating to financial years 2017-18 and 2018-19 - HELD THAT:- As notice u/s 148A(b) of the Act and on the top of which it has been clearly described that the aforesaid notice has been issued relating to financial year 2015- 16/assessment year 2016-17. In the body of the annexure to the impugned notice u/s 148A(b) incidentally AO may have recorded some transaction rel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ioner has tried to make out a baseless and frivolous case not sustainable in law by creating an impression as if the impugned notice u/s 148A(b) and the order u/s 148A(d) and subsequent notice u/s 148 relates to three assessment years which is contrary to record on the face of it. WP dismissed. - Hon'ble Justice Md. Nizamuddin For the Petitioner : Mr. Pranit Bag, Adv., Mr. Anujit Mookherji, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 8A(b) of the Act and on the top of which it has been clearly described that the aforesaid notice has been issued relating to financial year 2015- 16/assessment year 2016-17. In the body of the annexure to the impugned notice under Section 148A(b) of the Act incidentally the assessing officer may have recorded some transaction relating to some other financial years, on the perusal of the aforesaid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the considered view that the petitioner has tried to make out a baseless and frivolous case not sustainable in law by creating an impression as if the impugned notice under Section 148A(b) of the Act and the order under Section 148A(d) of the Act and subsequent notice under Section 148 of the Act relates to three assessment years which is contrary to record on the face of it. Accordingly, this wr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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