TaxTMI 
TaxTMI 
2021 (9) TMI 1006
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....2019 issued under Section 148 of the Income Tax Act, 1961 (hereinafter 'the said Act') with the following prayers: - "(A) Your Lordships may be pleased to admit and allow this petition. (B) Your Lordships may be pleased to issue a writ of certiorari or a writ in the nature of certiorari or any other appropriate writ, order or direction for quashing and setting aside the impugned notice dated 29.03.2019 u/s 148 of the Income Tax Act, 1961 at Annexure-A and the order dated 18.09.2019 disposing the objections at Annexure-H. (C) Pending admission, hearing and final disposal of the present petition, be pleased to stay the implementation, operation and execution of the impugned notice dated 29.03.2019 u/s 148 of the Income Tax Act, 1961 a....
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....edger account of Excise Duty/VAT account of Rs. 10,10,69,972/-; (v) The details of month wise purchase and sales; (vi) The production of books of accounts, bills and vouchers for verification. 2.4. The petitioner submitted its reply on 22.07.2014. A further reply also came to be filed on 06.08.2014 giving more details. During the course of assessment proceedings under Section 143(3) of the said Act, the AO issued notice to M/s. Satva Merchandise Private Limited for calling for above such details. The notice was issued under Section 133(6) as also under Section 142(1) of the said Act. 2.5. After considering all the details, the assessment under Section 143(3) was ordered on 07.11.2014 and the income was determined as mentioned herei....
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.... assessment is not justifiable and hence, this petition. 3. On issuance of notice and grant of interim relief of not to further proceed with the proceedings pursuant to the impugned notice, the other side appeared and filed his affidavit-in-reply denying all the allegations. 3.1. According to the respondent, the information had been received in relation to Rajkot Nagrik Sahkari Bank Limited and Axis Bank Limited. The assessee company had credited Rs. 1,48,70,52,060/- in current account No. 38/3385 with Rajkot Nagrik Sahkari Bank Limited and Rs. 15,54,73,416/- in the current account No. 910020027703814 with Axis Bank Limited. In order to ascertain how bank transaction treated in books of account, the DDIT(Investment) issued summons under S....
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....t was duly served upon the assessee company. In response to the said notice, assessee company had filed its return of income on 29.04.2019 and declared the same income as filed in the original return of income show in the assessment year on 2012-2013. The reasons recorded for reopening of the assessment were provided to the assessee company on 18.07.2019. 3.4. According to the respondent, Central Bank of India, Ahmedabad has lodged a criminal complaint with CBI regarding fraud, cheating and other offences committed by M/s Ardor International Private Limited, Mr. Fenil B. Shah, Mr. Bharat Rasiklal Shah, Smt. Geetaben B. Shah (Director of assessee company M/s. Satva Merchandise Private Limited) in respect of various credit facilities extende....