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TMI Blog2024 (11) TMI 1443X X X X Extracts X X X X X X X X Extracts X X X X ..... thiyanarayanan For the Respondent : Mr.S.Rajasekar Standing Counsel ORDER In this Writ Petition, the petitioner has challenged the impugned notice dated 30.03.2021 issued under Section 148 of the Income Tax Act, 1961 for the assessment year 2014-15. Pursuant to the above notice, the assessment that was earlier completed on 29.01.2018 under Section 143(3) read with Section 92CA read with Sect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1/5 th share issue expenses of Rs.37,60,13,629/- and for general corporate purpose and issue expenses Rs.160,84,09,967/- were all subject matter of scrutiny before the assessment order dated 29.01.2018 was passed. 4. Specifically, a reference was made to the response of the petitioner dated 22.06.2016 in response to notice issued under 143(2) of the Income Tax Act, 1961 on 28.08.2015, which was r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... reliance of the judgement of the Hon'ble Supreme Court in Calcutta Discount Co.Ltd Vs. Income-tax officer reported in 1961 41 ITR 191 SC and also placed reliance on the judgement of this Court in The Principal Commissioner of Income Tax Vs M/s. Mansi Finance (Chennai) Ltd in Tax Case Appeal No.71 of 2021. 7. That apart, the learned counsel for the petitioner submitted that, in the absence of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt has merely brought out the point that, as stated in the reasons recorded and also detailed discussion in the said order is apparent that the AO has necessary information in his possession that assessee company had abandoned projects in respect of which it has claimed depreciation at a rate higher than what it was entitled to which it has claimed and projects for which it has claimed deduction u ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... out the same. Therefore, there is no merits in challenge to impugned notice dated 30.03.2021 or the speaking order dated 24.01.2022, as the petitioner has not given the true and full disclosure of all material information before the assessment was passed on 29.01.2018. Therefore, the Writ Petition is liable to be dismissed. 13. Accordingly, the Writ Petition is dismissed. Consequently, connected ..... X X X X Extracts X X X X X X X X Extracts X X X X
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