9911796707
TMI Blog2024 (3) TMI 1376X X X X Extracts X X X X X X X X Extracts X X X X ..... taking into consideration that the reassessment is initiated vide impugned notice issued on 26.03.2023 in relation to Assessment Year 2012-13 and also the provisions contained in Section 149(1)(b) of the Act, as amended vide Finance Act, 2021, pre-existing provisions of Section 149 and Section 153C as also the orders passed by the different High Courts, the petitioner has made out a strong prima-f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gh number of grounds have been urged in the petition to challenge the order of re-assessment, as notice under Section 148 of the Act is apparently time barred, the proceedings are without jurisdiction and, therefore, the respondents be restrained from proceeding further with the assessment proceedings. His submission is that by the impugned notice under Section 148 of the Act, the respondents have ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... le-1, Trichy [W.P. (MD) No. 4327/2021], the order dated 15.09.2023 of the Delhi High Court in the case of Filatex India Ltd. vs. Deputy Commissioner of Income Tax Anr. [W.P. (C) No. 12148/2023], and the order dated 02.05.2023 of the Delhi High Court in the case of Alankit Insurance TPA Limited vs. Dy. Commissioner of Income Tax Circle 28, Delhi [W.P. (C) No. 5643/2023], it is argued that the petit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rson, revealed various bogus entries between the present petitioner and the person whose premises were searched and there is enough material to make out a primafacie case. He would submit that presently the assessee is not being assessed, but only assessment has been reopened. 5. Having considered the submissions of learned counsel for the parties and particularly taking into consideration that th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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