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TMI Blog2023 (2) TMI 1360X X X X Extracts X X X X X X X X Extracts X X X X ..... nsent of the counsel for the parties, the writ petition is taken up final hearing and disposal, at this stage itself. 3. This writ petition came up for hearing, in the first instance, on 23.01.2023. At that juncture, Mr Agarwal had raised a preliminary objection, which is, that the order qua which grievance was articulated in the writ petition was passed as far back as on 31.03.2022. 4. This order was passed under Section 148A(d) of the Income Tax Act, 1961 [in short, "Act"]. 5. Having regard to the objection taken, we had asked Mr Agarwal to return with instructions, as to whether or not in the intervening period, the Assessing Officer [AO] had passed an assessment order. 5.1 Mr Agarwal has returned with instructions, to the effect tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rementioned information is contained in the "Annexure" appended to the notice dated 23.03.2022 issued to the petitioner under Section 148A(b) of the Act. 10. We have, on record, the reply dated 26.03.2022 filed by the petitioner to the aforementioned notice. Briefly, the petitioner has denied having entered into transactions in the period under consideration with the entities referred to hereinabove. 11. We have asked Ms Rano Jain, who appears on behalf of the petitioner, as to whether any information/material was furnished to the petitioner, which linked the petitioner to the aforementioned entities. Ms Jain emphatically submits, that no information/material was supplied. 11.1 As a matter of fact, Ms Jain also submits, that the informat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ice, both of which are dated 31.03.2022, with a direction to the AO to carry out a de novo exercise. 15.1 It is ordered accordingly. 16. However, before commencing this exercise, the AO will furnish necessary information/material, which links, according to him, the petitioner to the entities referred to in the notice issued under Section 148A(b) of the Act. 16.1 If such information/material is furnished to the petitioner, the petitioner will be granted liberty to file a supplementary reply. 16.2 For this purpose, two weeks will be granted to the petitioner. 16.3 The AO will, thereafter, deal with the objections of the petitioner and pass a speaking order; a copy of which will be furnished to the petitioner. 17. We are informed by Mr A ..... X X X X Extracts X X X X X X X X Extracts X X X X
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