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TMI Blog2024 (5) TMI 1460X X X X Extracts X X X X X X X X Extracts X X X X ..... 148A(d) and which have been extracted hereinabove. Quite apart from the issue of Section 68 which may arise, we are concerned with the allegation of diversion of income. We also bear in mind that at the stage of initiation of action for reassessment, the writ court would only consider whether the AO had duly applied its mind with respect to aspects pertaining to escapement of income. As is evident on a consideration of the conclusions tentatively arrived at by that authority and which constitutes its prima facie opinion, it cannot be said that the authority has failed to bear in consideration the principles that govern the commencement of action under Section 148 or that the opinion formed is wholly untenable or perverse. Writ petitions sha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in relation to a trust Legal Initiative for Forest and Environment were diverted to the account of the petitioner and that no professional services were either rendered or details thereof furnished. 3. We note that the respondent has while disposing of the objection which had been preferred, rendered the following observations:- 5.3.7 Also, the assessee has submitted that the sum received for AY 2017-18 from Earth Justice is for the advisory/ legal research services and enclosed a paper in his reply wherein plain details have been mentioned for various piece of works. However, no supporting documents are enclosed to substantiate that these works were actually carried out such as copy of email communication, various reports etc. The assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ritwick Dutta has only provided update of status of litigation related to thermal power plants. Ritwick Dutta in association with Earth Justice is discussing strategies to put pressure on Indian or State Governments or project proponent. Planning targeting projects of Indian entities in foreign jurisdictions which can be challenged there. Attempt to create litigation and stalling thermal power plants. No proof of any retainership or any agreement reflecting the rates of advice or opinion given by assessee. 4. Mr. Jolly, learned counsel appearing in support of the writ petition would contend that the details of these services had been duly provided to the respondents while replying to the notice under Section 148A(b) of the Act. It was furth ..... X X X X Extracts X X X X X X X X Extracts X X X X
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