2018 (3) TMI 585

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....RDER P. C. Heard. 2 RULE. 3 This Petition under Article 226 of the Constitution of India, challenges a notice dated 30th March, 2017 issued by the Commissioner of Income Tax under Sections 148 of the Income Tax Act, 1961 (the Act), for the Assessment Year 2010-11. 4 The reasons in support of the impugned notice refers to a purchase of 40 lakhs shares of one M/s. Knight Riders Sports Pvt. Ltd.....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ection 56 of the Act. 5 Petitioner filed its objections. In its objections, it was particularly pointed out the valuation report of the Government approved valuer was not furnished to them along with the reasons. Allthough the recorded reasons state that it is annexed thereto. In any case, the objections points out that there was no income. The reasons proceed on the basis that in view of short p....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....he contentions raised by the Petitioner. 6 The entire exercise of raising objections and the Assessing Officer taking second look at the impugned notice is turned into an empty formality, if the objections are not taken into consideration while disposing of the same. 7 Be that as it may, prima facie, the Assessing Officer could not have any reason to believe that income chargeable to tax has esc....