2021 (8) TMI 130

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....ent Systems Company' with domain expertise in the areas of financial transaction processing and payment solution and its expertise include transaction switching & payment systems; debit, prepaid, smart and credit cards processing; front-end devices, host systems & interchanges; internet & Mobile payments; merchant management; system integration, financial inclusion & micro banking. 3. The petitioner filed its return of income electronically for the Assessment Year 2010 - 11 on 02.10.2010 returning a total income of Rs. 39,58,67,100/- after claiming deduction under Section 10 B of the Act. The respondent initiated the assessment proceedings by issuing notice under Section 143 (2) of the Act, followed by various notices under Section 142....

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....be set aside. 6. The learned counsel for the petitioner reiterated that the validity of jurisdiction to initiate reassessment proceedings is also an objection raised. This apart, the details with regard to issue of shares was provided in letter dated 09.11.2012 and details of expenses relating to issue of shares is provided in letter dated 05.12.2012. None of these letters were considered by the Assessing Officer and no findings are given in the order impugned. Thus, the matter is to be remanded back for fresh consideration.   7. The learned Standing Counsel appearing on behalf of the respondents objected the said contention by stating that perusal of the objections would reveal that the petitioner has raised validity of jurisdiction....

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.... 9. The learned counsel for the petitioner also in its objections referred few judgments of the Constitutional Courts and the learned Standing Counsel for the respondents also referred judgments in their favour. High Court cannot conduct a roving enquiry with reference to the facts and details which are to be scrutinized and ascertained through the original documents and evidences. If the reasons furnished are sufficient and if the objections are dealt with in accordance with the provisions of the Act, it would be sufficient for the requirement to be complied with. At the initial stage, one cannot expect that entire facts are to be adjudicated. It is only initiation of reopening of proceedings and notice was issued, thereafter objections w....