9911796707
TMI Blog2024 (10) TMI 1482X X X X Extracts X X X X X X X X Extracts X X X X ..... os. 20756 and 20757 of 2021 - - X X X X Extracts X X X X X X X X Extracts X X X X ..... bitions and had sold business to M/s. International Trade and Exhibition India Pvt. Ltd by an agreement dated 02.05.2012 which accompanied another non-compete and non-solicitation agreement also dated 02.05.2012. 5. It is therefore submitted that the Impugned Notice and the Order disposing of the objection/overruling the objection of the Petitioner are liable to be interfered in the light of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er Section 143(3) read with 147 of the Income Tax Act, 1961. Hence, he prays for dismissal of the present Writ Petition. 9. Having considered the submissions made by the learned counsel for the Petitioner and the learned Senior Standing Counsel for the Respondent and having perused the documents filed before this Court, it is evident that the Petitioner had furnished all the documents required fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r expiry of four (4) years, the Department could have invoked Section 147 of the Income Tax Act, 1961, only if tangible materials were available and that there was failure on the part of the Petitioner to disclose materials/documents and informations which were required for completing the assessment under Section 143(3) of the Income Tax Act, 1961. 12. In the result, the Writ Petition stands allo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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