2019 (6) TMI 1641

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....dvocate For Mr.Srinath Sridevan For Respondent : Mr.G.Rajagopalan Additional Solicitor General Assisted by Mr.Karthik Ranganathan Senior Standing Counsel for Income Tax Department ORDER The show-cause notice seeking explanation / reply as to why the Assessment of AY-2014-2015 made under Section 143 (3) read with Section 92 CA of the Income Tax Act, (in short "Act") dated 31.12.2016, shoul....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ax, Large Taxpayer Unit-I, accepted the Return filed by the petitioner and passed orders on 31.12.2016. 3. In the year 2017, notices were issued to the petitioner's shareholders viz., Cognizant (Mauritius) Limited and Cognizant Technology Solutions Corporation, United States, on the ground of over valuation of shares. The shareholders of the petitioner have challenged the Draft Assessment O....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....r Section 77 A of the Companies Act cannot be regarded as dividend and the impugned notice has been issued in a hurried manner without providing sufficient time to the petitioner to send a reply and hence, it is liable to be set-aside. 5. In reply, Mr.G.Rajagopalan, learned Additional Solicitor General on behalf of the Revenue would argue that the order impugned in this Writ Petition is on....