TMI Blog2024 (6) TMI 543X X X X Extracts X X X X X X X X Extracts X X X X ..... . For the Respondents : Mr. Shlok Chandra, SSC with Ms. Madhavi Shukla & Ms. Priya Sarkar, JSCs & Mr. Sudarshan Roy, Adv. ORDER CM APPL. 25439/2024 (Exemption) 1. Allowed, subject to all just exceptions. 2. Application stands disposed of. W.P.(C) 6127/2024 & CM APPL. 25438/2024 (Stay) 3. The writ petitioner impugns the order under Section 148A(d) of the Income Tax Act, 1961 ["Act"] dated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion 148 of the Income tax Act, 1961 should not be issued. 3. You may submit your reply to this notice, along with supporting documents (if any) on the above mentioned issues on or before 29/03/2024 electronically at www.incometax.gov.in." xxxx xxxx xxxx ANNEXURE Background : - 1.1. The case of the assessee has been flagged as the potential case as per ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tries to the tune of Rs.1,61,19,174/- (debit : Rs. 1,52,00,000 and credit of Rs. 9,19,174), seem to be bogus and non-genuine for the assessment year under consideration. 3. In view of the above, an amount of Rs. 1,61,19,174/- appears to have escaped assessment for the AY. 2017-18 which needs to be brought to tax by issuing notice u/s 148 of the Income Tax Act, 1961. 4. Accordingly, you are her ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... transferee company for the relevant Assessment Year. You are also required to provide a copy of the order of the relevant authority/court ordering merger/amalgamation. RAVINDER GUPTA CIRCLE 13(1), DELHI" 4. As is manifest from the above, the respondents appear to have taken into consideration certain bank statements pertaining to M/s Metal Impex, Prop. Sh. Naveen Tayal ["Metal Impex"] with wh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ered opinion, therefore, the writ petitioner has failed to make out a case which may warrant interference under Article 226 of the Constitution. The writ petition shall consequently stand dismissed.
7. This order, however, shall be without prejudice to the rights and contentions of the petitioner which shall be open to be addressed before the Assessing Officer. X X X X Extracts X X X X X X X X Extracts X X X X
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