Court instructs thorough review by AO for challenged notices under Income Tax Act. Parties agree to resolution.

The court directed the Assessing Officer (AO) to thoroughly review all responses on record before finalizing the assessment for the challenged notices under the Income Tax Act, 1961. Additional time was provided to the AO due to the approaching assessment deadline. The parties agreed to resolve the matter in accordance with the court's instructions, emphasizing the importance of considering all submissions before concluding the assessment for Assessment Year 2018-19.

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Issues Involved:
The writ petition challenges an order passed under Section 148A(d) and a show-cause notice under Section 148 of the Income Tax Act, 1961. The challenge also extends to a show-cause notice dated 15.03.2022 issued under Section 148A(b) of the Act.

Challenge to Order and Notices:
The impugned notices and order pertain to Assessment Year (AY) 2018-19. The petitioner is alleged to have engaged in transactions with RCI Industries and Technologies Limited involving bogus increase in share capital and purchase bills. The AO issued notices under Section 148A(b) and 148A(d) based on these allegations.

Contention and Explanation:
The AO's contentions regarding the petitioner's transactions with RCI were outlined in the notices and order. Despite lack of clarity, the AO's position was explained by the senior standing counsel for the respondents/revenue. The petitioner did not initially reply to the notices but later submitted responses.

Approval and Compliance:
There is a dispute regarding the timing of approvals for the notices and order. The petitioner argues that approvals were obtained before the order was passed, while the respondents defend the approval process. The common reference number on the notices and order raises questions about procedural compliance.

Additional Responses and Scrutiny:
The petitioner provided further replies to the show-cause notices, emphasizing scrutiny of share capital issues in a previous order. The connection between the increase in share capital and transactions with RCI was not clearly established in the notices and order.

Decision and Directions:
The court urged the AO to consider all responses on record before proceeding with the assessment. Additional time was granted for the AO to make a decision, considering the impending deadline for completing the assessment. Both parties agreed to dispose of the writ petition based on the directions issued by the court.

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